Very interesting. Interesting that such a small bank had foreign correspondent issues. Also interesting about being ordered to cease providing RDC to MSBs until proper systems and processes are in place.
_________________________ Kathleen O. Blanchard, CRCM "Kaybee" HMDA/CRA Training/Consulting/Mapping The HMDA Academy www.kaybeescomplianceinsights.com
Two other small banks got nailed with C & D's as well. The OCC is not messing around.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu