New person in Compliance

Posted By: Scott832

New person in Compliance - 08/30/11 02:32 PM

Hello BOL'ers. I joined here about a week ago because I was getting in to a world that was highly technical and detailed. I just got promoted into a new compliance position at my credit union and I'm trying to catch up on whatever I can. I've searched this forum and homepage about 5 times a day since I started in my new role about 3 weeks ago. We've never had a compliance "person" before, so I get the joy of going over everything we do and evaluating it. So, my questions are:

1. What are the best training sessions (interactive preferably) to take when it comes to BSA/AML/OFAC? I already downloaded the "FRAML for Dummies" book!

2. Anybody know of a good place to go for 'best practices' on SAR's? We had an internal audit about 3 weeks ago and she said we were filing way too many SAR's.

3. Compliance "start-up" kit? Really anything I can use to evaluate my credit union? I figured I'd go through the last 5 or so audits and look at the findings and start there.

As I've been noticing, this board is full of highly knowledgeable people. Any suggestions on where to "start" would certainly help. Thanks!
Posted By: Princess Romeo

Re: New person in Compliance - 08/30/11 04:46 PM

When you say Compliance - are you talking just BSA/AML/OFAC or does that include the myriad of other compliance issues that pertain to Credit Unions such as the alphabet soup of consumer protection (Reg's B, E, CC, V, Z, RESPA, TISA, etc.) as well as Information Security, Record Retention, and Member Business loans?

Also - how large is your credit union - Assets/# of branches?

Depending on the size and complexity of your institution and the scope of what you need to assess and review, you may be able to do this yourself or you may need outside assistance.

You might try contacting CUNA and NAFCU for some of their compliance resource information. For BSA/AML/OFAC, you should probably start by conducting a Risk Assessment. BOL has some resources you check look into - http://www.bankersonline.com/bankerstore/bsaintropage.html

If you think you may need outside assistance, there are a number of knowledgeable consultants who post on this board.
Posted By: E.E.G.B

Re: New person in Compliance - 08/30/11 08:55 PM

Welcome!! To BOL and to the wonderful world of Compliance. grin

To your questions:
Originally Posted By: Scott832
So, my questions are:

1. What are the best training sessions (interactive preferably) to take when it comes to BSA/AML/OFAC? I already downloaded the "FRAML for Dummies" book! In your case I'd probably look for a good "BSA 101" type seminar. Professional Bank Services offers one and I'm fairly certain they do Houston as one of their stops. If you can talk your CU into it, Texas Bankers Assoc has a whole BSA school too. I think as a beginner you're better off going to an in-person session, because others will ask questions that you don't think of, and you can benefit from that. Not to mention the networking of people in approximately the same situation as you.

2. Anybody know of a good place to go for 'best practices' on SAR's? We had an internal audit about 3 weeks ago and she said we were filing way too many SAR's. Some of that is going to come with experience. Also, just reading the SAR instructions may help some. FinCEN's "SAR Activity Review" is an excellent resource as well. http://www.fincen.gov/news_room/rp/sar_tti.html


3. Compliance "start-up" kit? Really anything I can use to evaluate my credit union? I figured I'd go through the last 5 or so audits and look at the findings and start there. Great starting point. Pull the last couple of examinations, too. Another idea is to get the NCUA's exam procedures and work through those. Using what the examiners use will prepare you for their questions / comments.
Posted By: Reads Regs

Re: New person in Compliance - 08/30/11 09:04 PM

Have you seen the FFIEC's BSA/AML InfoBase? http://www.ffiec.gov/bsa_aml_infobase/default.htm
Posted By: *W*W*

Re: New person in Compliance - 08/30/11 10:16 PM

If you need BSA training, TBA's BSA/AML School is awesome!! It's offered every summer so you just missed it.

TBA also has a Compliance School that is great! I think there were some CU attendees the year I went. That was suggested to me by an examiner when I took over compliance for my bank.

Bankers Online Info Vault, Alphabet Soup, and Bankers' Threads will help ease alot of the growing pains too. Good Luck!
Posted By: Scott832

Re: New person in Compliance - 08/31/11 04:07 PM

All good info and thanks for the help. Our CU is about $215M in assets and we have 3 branches. And my role is general compliance. I will be looking at everything from BSA to Reg Z, Fannie Mae/Freddie Mac, the Credit Card Reform act, and other regs that are coming out and changes that go into effect this year. I also will be auditing some loans, new accounts, interest postings, etc. Most of this stuff I'm already familiar with because of my previous position here, but some of the more particular and technical issues with BSA, AML, and other more detailed aspects definately need to be further researched.
Posted By: BC78a

Re: New person in Compliance - 08/31/11 06:25 PM

I never heard of being criticized for too many SARs. I have heard of being criticized for meaningless SARs (Defensive SARs). If you have a sound belief that the activity is suspicious, you should file, regardless if it number 1 or number 1,000. At a prior job we averaged about 975/year ($2 bill bank)
Posted By: Sing A Little

Re: New person in Compliance - 09/01/11 03:05 PM

I agree with BC. No offense to your auditor, but I'd would wait until you hear the "too many SARs" comment from a regulator before you make serious changes. It probably wouldn't hurt to re-visit your procedures and make sure you have documentation of the reasoning behind your SAR filings.
Posted By: Matt_B

Re: New person in Compliance - 09/06/11 09:50 PM

Hey Scott, I'm in a pretty similar boat. New CU position for compliance, in charge of the whole range, internally promoted with a lot of catching up to do! Started Aug 1, 5 branches and around $250 million in assets.

This has been a great forum so far and I'm going to utilize several of the suggesitons/resources in this thread! If you have anything you find particularly helpful, I'd be interested and will gladly share the same.