You know, after reviewing a lot of material on BSA Risk Assessment, etc., etc., blah, blah, and blah, the thought occured to me:

The idea behind conducting a bank wide BSA Risk Assessment is not unlike the idea of establishing a Performance Context for CRA.

Think about it - you are establishing the backdrop against which your BSA/AML/OFAC performance will be measured. Which areas require additional attention? Which areas have enough in place? Not unlike credit needs assessment and what is already covered to death by your peers in CRA.

Well - what can I say? A few days of freedom, and the mind starts to wander......

It a very good analogy! You are setting the context in which your program will operate. Amazing what some time off will do.

We should hold seminars where we can sit and ponder these things. A BSA thinkk tank. That is what I miss about a big bank. There were lots of people to bounce ideas off of, etc. You didn't have to go far for a peer group!

There are actually a couple areas where the work the bank has already done for CRA should simply be modified for use in its BSA/AML risk assessment. For example, its assessment area for CRA should be the basis for its "geography" for the BSA/AML risk assessment. In addition, the products and services it lists in its public file should be the foundation for those inventoried in the risk assessment.

While the overlap between the two regulatory regimes is definitely more coincidental than planned, using the earlier CRA work product makes the BSA/AML risk assessment more defensible and easier to develop. It also eliminates the possibility that an outside evaluator could observe that, due to variations between the various documents, it is pretty obvious that the bank's left hand has no idea what the right hand is doing and that both compliance efforts are questionable.

kaybee,

In CA, the California Bankers Assn. is putting on a seminar to discuss the new exam procedures and how to do a risk assessment. This will be the new big thing in BSA - we all need to do one.

Agree, I found my CRA Officer a BIG help with the geographies part of the risk assessment. I look forward to Ken's webinar next month on risk assessments.

An observation - - a completed BSA/AML risk assessment contains strategic bank information. I'm sorry, but I would not want to share my risk assessment with others. Not that I don't want to help someone out, but I wouldn't feel right letting that degree of internal information and analysis go out the door . I'm sure my CEO would agree. I caution readers to consider this before asking other bankers for a copy of theirs. However, sharing a format or outline would not be too much.

I agree - the format can be shared. The results are proprietary. It is okay to discuss a thought process, I believe (how would you treat x?).