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TIAA-CREF Trust Company, FSB,

St Louis
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On June 28, 2013, the Office of the Comptroller of the Currency issued a Consent Cease and Desist Order to TIAA-CREF Trust Company, FSB, St. Louis, Missouri (Bank).

The Bank is a federally chartered savings bank with its only office located in St. Louis, Missouri. Its FDIC-reported financials for March 31, 2013, show a 236% growth in total assets over March 31, 2012 ($681 million to $2287 million), and a growth in staffing from 74 to 105 FTEs. The company was established in 1998.

The C&D Order has several articles requiring the bank's board to ensure it has competent management, a viable strategic plan, a capital plan, and improved management of its liquidity, funding concentration, interest rate risk and information security. Several articles, however, focus on BSA/AML concerns, requiring the bank to develop of put into place—

  1. a comprehensive BSA action plan
  2. a BSA risk assessment
  3. BSA independent testing
  4. BSA internal controls and high risk identification
  5. CDD and EDD information gathering
  6. a written program to ensure compliance with SAR filing requirements
  7. BSA training
  8. appropriate BSA compliance department staffing

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