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Compliance Action, Volume 23, Number 1

February 28, 2018

*** From the Editor: A belated Happy New Year ***


Many of you noticed we are beginning this year just a little late. Behind the scenes, we have been hard at work. Last year, we began adding the articles to the website as they were written instead of waiting until an issue was complete. A little later in the year, we began experimenting with "double issues". The feedback on both efforts was extremely positive and we have decided to change our editorial calendar to allow us to include longer articles and more charts and checklists - along with the other content you have come to expect.

What was an occasional double issue will now become standard each month. And we're not finished. We are also working on a slightly redesigned .pdf format that will be introduced in the next several months along with other changes that we will announce as the year progresses. The next several weeks will see an increased pace of content being introduced to the site as we "catch up" and we will alert you when each issue is complete. But don't wait for the email. Check back frequently and catch the new content as it is published!

- Patti Joyner Blenden, Editor



How Do You Measure the Culture of Compliance? (2 Action Steps)

by by Rob Rowe

An important element to ensuring compliance wasn’t just strictly following the rules. Following the rules is, without a doubt, extremely important. But since not everything is black-and-white or check-the-box, having a corporate culture to “do the right thing” is vital to any successful organization. So what do the regulators want?

It’s 2018. Do You Know How to Handle a Marijuana Business?

by Rob Rowe

Today, there are 29 states that allow the use of some form of cannabis for medicinal purposes and another nine states that permit recreational or adult use. Every state varies in what’s required to legally obtain and operate under a license. The question, though, is what’s happening at the federal level since federal law determines priorities where banks are concerned.

Prepaid Rule Delayed

The CFPB has extended the effective date of its rule on prepaid products to facilitate finalizing the Agency's new modifications to several aspects of the rule.

Phase I and Phase II Exemption from Currency Transaction Reporting Quick Reference (Chart)

by Patti Blenden

FinCEN guidance on determining eligibility for exemption from CTRs clarified the variety of supporting information suitable for substantiating that certain business customers engaging in multiple business activities are eligible for CTR exemption. Many are not. This chart will help keep your options organized.

Compliance Notes

Compliance Calendar

In the Editor's Opinion
Slow and Steady Wins the Race

by Patti Blenden

CFPB Releases Strategic Plan

by Patti Blenden

The CFPB released its latest five-year Strategic Plan (2018 - 2022) establishing its mission, strategic goals, and strategic objectives as required by the Dodd-Frank Act.

Regulation CC Hold Reasons Quick Reference Guide: Consumer And Commercial Accounts (Chart)

by Patti Blenden

Reg CC doesn’t have to be a nightmare for frontline, deposit operations, compliance and audit personnel! Examples are provided to help your staff understand how to use the hold reasons.

Compliance Q & A

FinCEN Updates SAR Form

by Patti Blenden

In case you missed it, FinCEN recently announced revisions to the Suspicious Activity Report (SAR)

CFPB’s Final March 2018 Mortgage Servicing Rule

The CFPB issued a final rule to give mortgage servicers more latitude in providing periodic statements to consumers entering or exiting bankruptcy.

Editor:
Patti Joyner Blenden
Board of Advisors:
John S. Byrne, Esq.
Cliff E. Cook
David Dickinson
Julia A. Gliha, MBA
Michael D. Maher
Carl G. Pry
Robert G. Rowe, III, Esq.
Andy Zavoina

Compliance Action