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.

Jenny

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.

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.

5) borrowers using loan proceeds for something other than the stated-purpose.

I would review the red flags for lending from the recently revised FFIEC BSA/AML Exam Handbook. http://www.ffiec.gov/bsa_aml_infobase/documents/red_flags/Lending.pdf

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.

I have a powerpoint on the Red Flags, if you're interested.

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

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.