Compliance Related Attention Deficit Disorder
Attention Deficit Disorder
by Mary Beth Guard
Recently, I was diagnosed with CRADD:
This is how it manifests itself:
Today was the day I was going to circulate a memo to staff reminding them of our information security policies. The article about the OCC's latest action lit a fire under me.
I got to work early and was going to put Privacy Police warnings on desks where employees had failed to put away customer files for the night. Need to have a discussion on employee procedures, time management and getting organized, but first I have to find the manual.
Then I hear the ding of incoming email on my computer, so I race over to check and find new 314(a) search requests.
I start saving all 75 attachments and prepare to print them out. While the printer is warming up, I decide to check the Threads on BankersOnline to see if there is anything new about the search requests that I should know about.
While looking for posts on 314(a), I come across a thread that indicates the 326 final rules on CIP will be coming out in less than two weeks. Darn it, two weeks! I go back to the front page of BOL so I can click over to the AML/USA PATRIOT section of the site to see if anything has been issued. Has anything been issued. . . Uh . . . what hasn't been issued?
Before I can scroll down and click, I get an email about another OFAC change! We've got to buy OFAC software. This is killing me, and that article on OFAC civil penalties made for a sleepless night the other night. Okay, I did sleep some, but I had OFAC and 314(a)-314(z) nightmares. There isn't a 314(z), is there?
I'm just about to print out the revised OFAC list when I spot a car being parked INSIDE the bank lobby. What in the world?!?!?! Our smiling marketing officer informs me that a local school is raffling it off and we're going to sell raffle tickets. Marketing and Compliance -- the oil and water of the banking world!!!!
I need to call my doctor for a refill on my tranquilizers, but the phone rings before I can dial out. "Are you coming to the party we're throwing for local realtors tonight?", asks our chief of mortgage lending. "I'm trying to get a count." Can these people even SPELL RESPA???
Just then, I overhear my cubicle mate talking to a fellow employee. "This is the 10th large wire transfer this guy has made to Nigeria this month. Wonder what he's up to? He's supposed to be a janitor for a law firm. Can't imagine where he got all the cash." Janitors must have a higher status in Nigeria than in the US. Maybe my deadbeat son can move up in the world if we send him overseas. I peek over the top of the cubicle and ask, "What's the deal? Have you filed a SAR?" The startled employee slaps his forehead and says (BTW, Slapping his head and speaking at the same time is a big accomplishment for this fellow), "I knew there was something I was forgetting! Say, sweetheart, you're lookin' mighty sexy today. I think I may need to take some private compliance lessons, if you know what I mean. How about this evening at my place?"
I slink back into my cubicle. Where is that link for the Webinar on harassment? I really, really need to make sure he gets registered for that. And, then I'll send "Mr. Private Compliance Lesson" to Hong Kong for a case of SARS. No, I won't! Just a sudden brain lapse.
The President's secretary interrupts by handing me a memo. The Pres is concerned about all the time being spent on 314(a) requests and wants to know if we can just ignore them. "Yeah, you can ignore BSA. Just spend the money on a new set of golf clubs." Okay. I didn't say that. The thought just popped into my head.
Before I can draft a reply, one of our hotshot loan officers visits my desk. "Hey, I just heard on the radio there's a good chance of severe flooding across town. I have some mortgage loans in that area that I waived the flood insurance requirement on. I need you to draft something to the borrowers to tell them they have to get flood insurance now." Hey, yourself, goober. I'd like to put YOU underwater.
The next thing I know, it's time to go home and I'm trying to figure out why nothing got done today. Oh, crud my tranquilizers!
I'm tired. I know I was busy. I hope they find a cure for CRDD soon, but first a little reality TV to see who gets kicked off the island, gets married by America or is willing to consume insects for cash. I'd like to fill out a CTR on that deposit.
Copyright, Bankers Online. First published on BankersOnline.com 4/8/03; links updated 12/24/12
First published on 12/24/2012