Editor, Bankers' Hotline, North Port, FL
P. Kevin Smith is the VP of Asset Protection for Navient, Inc (formerly Sallie Mae, Inc.), a $200 billion student lending organization, headquartered in Newark, Delaware. He is the former Chief Security Officer for Cablevision in Bethpage, New York. From 1999 to 2010 he served as Corporate Security Director for Chevy Chase Bank in Bethesda, Maryland, a $15 Billion Federal Savings Bank with approximately 300 branches and 1,000 ATMs in the Baltimore/Washington Metropolitan area. Prior to that, Kevin was the Corporate Security Director for First American Bank in Nashville, Tennessee (1998-1999), and Wilmington Trust Company in Wilmington, Delaware (1987-1997). A retired Lieutenant from the Wilmington Police Department, Kevin holds a Master of Science degree in Administration, and a Bachelor of Science degree in Criminal Justice, both from West Chester University, in West Chester, Pennsylvania. He is a Certified Protection Professional through the American Society for Industrial Security (ASIS), Past Chairman of the ASIS Council for Banking & Financial Services, and a former member of the Bank Administration Institute's Security Commission. He has served on the Board of Directors for the Washington DC Police Foundation, was a member of the American Bankers Association Security Council and the past chairman of the Maryland Banker's Association Security Committee. Kevin has lectured nationally on a variety of bank security topics, and has been published in several security related periodicals. He is also the current Editor of Bankers' Hotline, a well respected monthly publication addressing current issues related to bank security and operations.
Areas of Expertise:
Bankers' Hotline Newsletter
Operational Risk Management
We have a frequent debate in our organization about how much of a background check is necessary for our employees, and whether or not we should perform background checks when a person is promoted or transferred. Can you please offer guidance on regulatory obligations or industry standards for background investigations?
Does a financial institution have the obligation to screen account beneficiaries for compliance with OFAC regulations?
Is it true that the Treasury Department has discontinued printing $2 bills?
I recently heard someone say they were the recipient of a call, where the suspect claimed to have kidnapped a family member, only to learn that the alleged victim was traveling and unharmed. Is this a common scheme to get money from people?
Are Codes of Conduct enforceable in the Banking industry? Are there any sample policies you can share with us?
Can a safe deposit box be declared "abandoned" and the contents turned over to the government?
Our Compliance Division has taken the position of not letting us know if a SAR has been filed on a matter that we refer to them for a potential SAR filing. Is there some sort of regulatory requirement prohibiting the confirmation of a SAR filing?
With regard to OFAC Compliance, I understand blocking a transaction, but what is meant by rejecting a transaction? When should a transaction be rejected rather than blocked?
For several years now, the most prevalent form of ATM fraud has been “Skimming”, where a device is attached to an ATM that captures magnetic stripe data as the card passes into a machine. We recently heard of a new ATM fraud technique called “Shimming”. Are they the same thing?
What is the timeframe for filing the FinCEN CTR? I have seen both 15 and 25 days referenced.