Compliance Action, Volume 24, Number 1
On May 2, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued a Framework for OFAC Compliance Commitments. In other words, guidance on the essential components of a sound OFAC sanctions compliance program.
The Criminal Division of the Department of Justice has released new guidance on evaluating corporate compliance programs.
Solicited Faxes are no Longer Junk
The so-called “Junk Fax Prevention” Rule has been in effect since 2005 and contains some specific rules with regard to unsolicited faxes. What may not be as well-known is that solicited fax advertisements (those that have been specifically authorized by the recipient) have also been subject to similar restrictions. But, recently, those restrictions have been eased.
The Application with an Identity Crisis
Incomplete applications have an identity crisis. They are unsure of what they are and how they want to be treated by their handlers. And, it’s no wonder. They might be an “Application” at one institution and an “Incomplete Application” at another. Let's all get on the same page.
The OCC’s Consent Order and Order for Civil Money Penalty indicated that the violations resulted from the bank’s relationship loan pricing program.
In the Editor's Opinion
FDIC to the Rescue for Robocalls?
You don’t usually think about the banking regulatory agencies as major robocall enforcers. That’s why it was interesting for me to see what the FDIC has done.
- Congress Extends Flood Insurance Program Temporarily
- OFAC Violation of Iranian Sanctions
- Fed Issues Supervisory Letter on BETR (Bank Exams Tailored to Risk)
- Agencies Issue Host State Loan to Deposit Ratios
Compliance Q & A
- Credit bureau disputes
- Can an employee sell real-estate part-time?
- E-sign and e-statements for consumers and businesses
Free FDIC Training
FDIC is offering a free, live 2-hour seminar that will provide a comprehensive overview of FDIC deposit insurance and resources.
- Nancy Castiglione
- Editor Emeritus:
- Lucy H. Griffin, Esq
- Board of Advisors:
- John S. Byrne, Esq.
Cliff E. Cook
Julie A. Gliha
Carl G. Pry
Susan A. Rich
Robert G. Rowe, III, Esq.