I started in BSA a few years ago and I built an Enhance Due Diligence program for higher risk customers with monthly transaction review and then yearly comprehensive review of the business and its expected vs actual activity. At the time I found a really clear outline of expectations in the BSA Manual and now I can't find anything related to EDD at a all. Did this get removed? Anyone else experiencing this?
If a SAR is submitted on the due date using an automated system is it considered to be on time or does it have to be accepted by FinCEN by the due date.
At what point in the process do we start conducting due diligence on loans and does it differ between loan and deposit accounts?
Does the Interagency Exam Manual for BSA include any training requirement for lenders?
May a lender delay the processing of a home loan application because an applicant is on maternity/paternity leave?
What does it mean to ensure my vendor is financially stable?
A person opens a DDA, is properly CIPd, and his name includes "Jr." as a suffix. Later, the same person, same SSN, borrows money without using the "Jr." suffix. Should the lender require the borrower to re-sign the promissory note using Jr. in the borrower's name?
Is there a requirement that lending agencies require proof of identity by coming in in person and giving a copy of a state issued ID before a loan is issued?
In the world of compliance, we sometimes face requirements that appear contradictory, what we like to call dueling regulations.
I'm the Internal Auditor of a community bank and will really appreciate your help with this. I'm working on the BSA Internal Audit and was trying to see if the FDIC/State requires for all employees to complete their BSA training, regardless of their department? We have a very good compliance program and training but it seems that some of the Loan department has not finish or even started with their online BSA training. Should I include as a recommendation to make sure that all employees complete their BSA training or should I write it up as violation? If you advise me to write it as a violation, give me good arguments because I have a stubborn Compliance Officer. Once again I would like to thank you for your time and assistance.