Skip to content
Thread Options
#670030 - 01/23/07 01:16 PM BSA Training (lending)
J2C Offline
Diamond Poster
Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
Good Morning.

I was wondering if anyone has an BSA training format that I could borrow geared toward lending staff? We are trying to really pin down specific areas and the only one left is lending.

If you are willing to share, please let me know!

Thanks in advance.

My opinion is mine only- not my employer's!

Return to Top
#670036 - 01/23/07 01:31 PM Re: BSA Training (lending) J2C
Skittles Offline
10K Club
Joined: Sep 2002
Posts: 13,963
Although I don't have a format I can tell you how I train the lending staff. I go over the CIP requirements, OFAC, and high risk accounts along with giving examples of suspicious activity that goes on with loans. Additionally I tell them basically about CTRs since loan payments can trigger them.

Hope this helps.
My Opinions Only

Return to Top
#670066 - 01/23/07 02:30 PM Re: BSA Training (lending) Skittles
BrendaC Offline
Power Poster
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
I particularly like to train on red flags for lenders. It isn't unusual to still find lenders that don't think BSA applies to them. I like to use real experiences whenever possible:
1) unexpected paydowns or payoffs (source of money?)
2) bad guys partnering with good guys to get into system (LLC owned by 2 other LLCs--who is ultimate benefactor?)
3) discrepancies in financial statements and/or tax records (two sets of books?)
4) unexplained variances in business activity

You get the idea.
Life without Jesus is like an unsharpened pencil - it has no point.

Return to Top
#670081 - 01/23/07 02:41 PM Re: BSA Training (lending) BrendaC
LoisLane Offline
Diamond Poster
Joined: Oct 2001
Posts: 1,570
Wisteria Lane..
5) borrowers using loan proceeds for something other than the stated-purpose.
And where is Superman when I need him?

Return to Top
#670422 - 01/23/07 06:53 PM Re: BSA Training (lending) J2C
Reads Regs Offline
Diamond Poster
Joined: Nov 2004
Posts: 2,294
I would review the red flags for lending from the recently revised FFIEC BSA/AML Exam Handbook.
Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.

Return to Top
#670535 - 01/23/07 08:07 PM Re: BSA Training (lending) Reads Regs
Trees Offline
Power Poster
Joined: Apr 2005
Posts: 4,013
You would probably get points from your examiners if you reference, or make available the recent Fincen reports "Mortgage Loan Fraud" (11/06) and "Money Laundering in the Commercial Real Estate Industry" (12/06). Some good stats (rising incidents), examples, etc. Also explain how and when lending can fit into the money-laundering cycle. I agree with the others - the more examples the better.

Return to Top
#670731 - 01/23/07 10:30 PM Re: BSA Training (lending) Trees
Rosie O'Grady Offline
Gold Star
Rosie O'Grady
Joined: Nov 2005
Posts: 438
I have a powerpoint on the Red Flags, if you're interested.

Return to Top
#670853 - 01/24/07 01:23 PM Re: BSA Training (lending) Rosie O'Grady

Rose, I'd like a copy of your powerpoint on Red Flags. You can send email to me at Thanks for sharing.

Return to Top
#670857 - 01/24/07 01:27 PM Re: BSA Training (lending)
DeeQ Offline
10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
I have a handout for our lending staff, PM me your email address and I will send it to you. I also have one for accounting.
Get your facts first, then you can distort them as you please. - Mark Twain

Return to Top

Moderator:  Andy_Z