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#351415 - 05/04/05 06:40 PM Re: FinCEN/Agencies issue MSB Interpretive Guidanc
John Burnett Offline
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John Burnett
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Unhappily, Ken, although the financial institution's regulator doesn't get to interpret the rules, it's often that agency's opinion that has the most impact on the financial institution, particularly in cases like this where there is no rule.
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#351416 - 05/04/05 06:43 PM Re: FinCEN/Agencies issue MSB Interpretive Guidanc
Princess Romeo Offline

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Joined: Jun 2001
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Quote:

Unhappily, Ken, although the financial institution's regulator doesn't get to interpret the rules, it's often that agency's opinion that has the most impact on the financial institution, particularly in cases like this where there is no rule.



That wouldn't be so bad except that you can have ONE person at your regulatory agency tell you something, but you probably won't get it in writing, and your examiner can have an entirely different opinion. Then guess what happens.......
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#351417 - 05/04/05 07:32 PM Re: FinCEN/Agencies issue MSB Interpretive Guidanc
Pinkie CRCM Offline
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Joined: Aug 2003
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KY
Would that fall into one of those "pick your battles" category? I would "like" to think John's response could prove beneficial during a disagreement between the examiner and management, especially if the imposition of CMPs are involved. Thoughts?

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