|
|
|
BSA/AML/CIP/OFAC Forum
|
|
Hi - I know as I'm typing this that the answer can be as short as 'well it depends'. I've been tasked by management to determine if the work load my BSA staff has is comparable to the industry. For example, if they average 30 alerts/cases a week, is that higher/lower than the average? This is in effort to ensure staff is working to their potential and not just getting by - as well as a tool for setting goals on their quarterly reviews. I realize that each case is not created equal, each alert is not created equal. So there is that element. I can easily pull numbers from my AML software. But the challenge is trying to compare that to an industry standard. I don't know where one would exist on this type of position. Any words of wisdom would be greatly appreciated. Thanks.
|
|
Chat! - BOL Watercooler
|
|
Kiss From A Rose - Seal
|
|
Chat! - BOL Watercooler
|
|
Shut Up And Drive - Rihanna
|
|
Marketing
|
|
If you go to https://www.fdic.gov/news/press-releases/2023/pr23110.html, and go to the body of the press release, below the official physical sign, you can click on the digital sign below it and save as a .png.
|
|
Marketing
|
|
That is what it appears like to me.
|
|
HMDA
|
|
I say not hmda reportable.
FWIW, I agree.
|
|
Flood Compliance
|
|
The check was mailed out by the Insurance agent, except it is still out to be delivered for processing. Since the check has not been processed yet, we were questioning if this will be be considered "in place".
|
|
General Discussion
|
|
For an advertisement, you really have no choice but to do so:
1030.3(f) Rounding and accuracy rules for rates and yields. (1) Rounding. The annual percentage yield, the annual percentage yield earned, and the interest rate shall be rounded to the nearest one-hundredth of one percentage point (.01%) and expressed to two decimal places. For account disclosures, the interest rate may be expressed to more than two decimal places.
|
|
Lending Compliance
|
|
If the loan itself was not subject to Regulation Z, then it would be exempt from everything, if that is what you are asking. The type of collateral is not a factor in determining Regulation Z coverage, only the loan purpose.
|
|
Need to Remain Anonymous
|
|
Many banks do not even allow partial withdrawals - it is all or nothing. What is your policy? Do you indicate that partial withdrawals are possible?
|
|
BSA/AML/CIP/OFAC Forum
|
|
I received an email that 314a is ready today and I was able to download. Look for your cheat sheet for the new system which will be active for the next 314a.
|
|
Lending Compliance
|
|
Thank you. Yes the Desktop states its own value which in this case was the same as the appraised value.
|
|
Chat! - BOL Watercooler
|
|
Bob Graham - Florida Governor and US Senator
|
|
Need to Remain Anonymous
|
|
Anon, I would fret because one of my bosses seemed similar to yours.
After the proverbially sounding "beat my head against the wall because it feels so good when I stop", I realized my job was to document and inform management of the laws, regulations and practices to the best of my abilities. It was management's decision and responsibility to take the appropriate course of action for the benefit of the bank. Once I got that through the brain, I was a lot happier. The Audit Committee asked and was apprised of all communication on the regulations, and they were aware of the situation. I lasted longer than the president or EVP.
(One "before" issue for example, - the EVP waived flood insurance on a loan. I told him, no-one in the bank is authorized to create a violation of federal law. His comment - I'm the boss and I can do whatever I want.)
|
|
BSA/AML/CIP/OFAC Forum
|
|
you would list them both as conducting on own behalf. Same as if they both came in to do a deposit together. They are present and you can see they both benefit from the cash.
|
|
CRA
|
|
The idea is not to collect data for the sake of collecting data. It's to collect accurate and meaningful data. I am sure that the credit decision was based on the financial information about the borrower you have in file, You wouldn't have extended the maturity date without some financial information and unless you know the GAR dropped below the $1MM level you must know that it remains above that level and I would suggest you code the GAR accordingly
|
|
Need to Remain Anonymous
|
|
Thank you everyone for the feedback so far!
No, no bankruptcy. The LLC created by the commercial borrower back then (which was the borrowing entity for both the bank loan and the private loan) was dissolved after the bank debt was settled. It no longer exists. The gutsy LO is going after the commercial borrower personally... even though there was no personal guarantee. (What's more... the LO told the commercial borrower back in 2008 to "tear up" the original promissory note when he didn't want it to be discoverable by the bank. He's now claiming it was a note personally to the commercial borrower's wife. Little does he know the commercial borrower kept his copy.)
I'm confident there is no basis for the private loan's collectability anymore... I'm just astounded by the LOs behavior (all around) and trying to determine if it should trigger any further action.
I think I'm just going to chalk this up as a "what not to do" story, and move on. Thanks again.
|
|
Need to Remain Anonymous
|
|
I also found someone that is recovering some of the money that I have lost.
I would tread very carefully here. The internet is full of repeat scammers who pose as law enforcement and instruct the victim to send more money to "catch the scammers in the act." In reality, the scam victim is being victimized a second time and sends more money to the same scammers.
|
|
Lending Compliance
|
|
Thank you very much for confirming!
|
|
Need to Remain Anonymous
|
|
Thanks for the responses!
|
|
RESPA
|
|
Use the TRID Date Calendar on BankersOnline https://www.bankersonline.com/tools/148863
|
|
Deposits and Payments
|
|
Thank you!
|
|
Lending Compliance
|
|
Thank you rlcarey. I feel like I'm losing my mind some days.
|
|
Marketing
|
|
Banker12 - I see nothing wrong with the target marketing, especially as redlining is minority tracts (not LMI). One thing you mentioned was, " general ads are published in the newspaper and TV for the entire assessment area."
While that is good, it might be beneficial to identify the demographics of the readership and viewers. That should be available from the newspaper and media companies. REASON - just because they are general circulation, does not mean that all audiences read/view it equally. While there may be 100% coverage, their readership/viewing demographics would be more important.
|
|
Operations Compliance
|
|
A link to the VISA rules can be found in this Q&A: https://www.bankersonline.com/qa/visa-cash-advance-rules
|
