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#625878 - 10/17/06 08:02 PM What are your biggest BSA challenges?????
Rangers Fan Offline
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Rangers Fan
Joined: Dec 2001
Posts: 345
Okay, it is input time and now is your chance to rant (a little) and give input about the things you wish you had to help comply with BSA. I am working on a graduate school of banking paper and the topic will be the challenges of complying with BSA for the smaller bank (assets of under $500,000). What are the main issues that others deal with? I know what my issues are (costs, people, automation, etc), but I would love to have some feedback on what you feel that you are at a disadvantage on if you are a small bank. If you have had BSA responsibilities for both a large and small bank, any input on challenges you have seen would also be great. I have great resources and references (and my own opinion), but I could really use some quotes from you guys (the experts) and this would make a much more effective impact on hearing from the folks in the trenches.

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#625879 - 10/17/06 08:30 PM Re: What are your biggest BSA challenges?????
ACBbank Online
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ACBbank
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New York City
As someone who was in charge of BSA/AML requirements at a multi million dollar FI and now a small FI( assests under 80 million) I would say from a small FI the main issue is providing the correct level of training to branch employees who have numerous duties throughout the day, as well as their customer service job functions. At a large FI, my biggest concern was accounts that were opened online. Performing DD and KYC was always a little more difficult for online accounts, IMO.
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#625880 - 10/18/06 02:08 AM Re: What are your biggest BSA challenges?????
Dazed and Confused Offline
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Dazed and Confused
Joined: Feb 2006
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Big XII South
Management's attitude and willingness to devote the necessary resources to ensure compliance. BSA/AML = cost of doing business ... but they don't always see it that way ... (yet) ...

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#625881 - 10/18/06 01:49 PM Re: What are your biggest BSA challenges?????
MadisonCali Offline
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One challenge at a very small institution is the fact that you often have to do it all yourself. There's simply not enough money (yet) to have any staff in the compliance department besides the officer, so all avenues lead to that one person.
Interpretations of regs are often difficult with nobody to bounce things off of (insert thanks for BOL here ).

The other big challenge is finding a way to convince people that you have to spend money and get things automated. Every bit of training, every bit of monitoring is done manually because of the small size (2 branches-can't justify the expense yet). Manual=Lots of extra time...
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#625882 - 10/18/06 02:21 PM Re: What are your biggest BSA challenges?????
Anonymous
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Ditto to MadisonCali...
Based on my understanding of the new/revised BSA/AML exam guide, what is being requested in relation to risk rating and on-going monitoring, to do this "right" it could only be done with a automated system. These systems cost upwards of $50,000 plus.
Example; how are you going to monitor ACH activity in every account to determine whether the activity is unusual?
We average over $2,000,000 a day in ACH activity. One person can NOT monitor these and do all the other BSA duties. Plus, at small banks this person usually is held by the compliance officer who is also the CRA officer. Those involved duties alone are full time positions.
No $, No help!

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#625883 - 10/18/06 03:04 PM Re: What are your biggest BSA challenges?????
MagicCity Offline

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MagicCity
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Fort Lauderdale, Florida
Even with an automated system, the level of monitoring required now is overwhelming.

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#625884 - 10/18/06 11:12 PM Re: What are your biggest BSA challenges?????
Darkhorse Offline
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Darkhorse
Joined: Nov 2004
Posts: 501
out of my mind
Ditto all that, plus a certain top manager who refused to support BSA efforts in their pet department (loans). Specifically that filing SARs on potential or existing loan customers will "get out in the community and cost us business" - uh, how exactly would that happen? Apparently "it just would"
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#625885 - 10/19/06 01:46 PM Re: What are your biggest BSA challenges?????
Rangers Fan Offline
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Thanks to everyone for their comments. I am glad to know I am not alone in the "feeling overwhemled" department. I know I lose enough sleep worrying about just compliance issues, but then dealing with the BSA issues on top of all of that can make one crazier than ever (can make for a really bad case of CRADD). Is it just me or does it seem to take a huge CMP to get exec. management's attention sometimes? I am blessed with management that for the most part is supportive and we have the green light to find automated software, but now we have vendor interface problems. Now the next huge task is to try to find an automated solution....oh yeah, and while I am reviewing large cash transactions, reviewing CTRs, and "why is this guy doing this in his account?" and "why don't these employees recognize this as suspious?" Do you sometimes feel like you are the only one in the bank who a) knows what suspicious activity is and b) will actually not be afraid to take steps and take care of it?

So in a dream world for a small banker doing BSA patrol, we want: management support, better training to have support folks (front line in this case) actually contributing, a big enough budget to get the automated software that we need/want, maybe a little help in general (like the understanding that what is required to have a tight program can be all-consuming and requires all hands on deck)....ah, but we can hope. And pray. Thanks to everyone's input. Hopefully the mini-rants helped too!

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#625886 - 10/23/06 04:04 PM Re: What are your biggest BSA challenges?????
BrendaC Offline
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BrendaC
Joined: Sep 2001
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Sweet Home AL
My current sore spot is the same--having to manually conduct CDD reviews of accounts of higher risk customers and exempt customers when we have a transaction profiling system that performs a "due diligence review" daily. It shouldn't be necessary if our transaction profiling system is working properly. We don't have the time or staff to support busy work.
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