Relative to BSA/AML, is there anything within FFIEC guidelines, or anything else for that matter, that states a bank must get the purpose for a wire/funds transfer? At a previous institution that I worked at we were cited by the OTS because we were not obtaining the purpose for a wire transfer. I have spoken to other colleagues and they, too have been cited; however, no one can find where this is an actual BSA requirement.
I have a loan that was denied. How do I report negative income on the HDMA LAR? Do I use NA?
We have been offering remote deposit capture for nearly two years. The FFIEC guidance issued in January, 2009 says institutions should do a risk assessment first. We didn't. Is it too late?
Do regulations require a specific pandemic flu "Policy". We are incorporating procedures for avian flu/pandemic in our disaster recovery plan. Is this sufficient?
A customer/owner wants to have his apartment property appraised using two methods- "as is" and "as if unimproved" (land value). After the appraisal is completed the customer wants to obtain a bank loan to finance either a rehab or new construction. Under FIRREA, can the bank engage the same appraiser and have the original reports updated?
What position (head teller, loan officer, etc.) of the bank would be the best candidate for our BSA officer? Would it be our compliance officer?
How in-depth should the training be for the Board of Directors in BSA? Is a general overview of BSA/AML/CIP along with an overview of the procedures in place sufficient for compliance?
Year-End Developments & Predictions
Disaster Planning for Pandemic Flu
by Jeff Patterson, MCSE, MCDBA, CDIA+, BOL Guru