Current expectations are that risk-rating should be fluid and customer risks reevaluated as monitoring identifies changes in business line, transaction volume, or ownership. Anticipated activity gathered at account opening should be compared to actual activity to aid in suspicious activity identification. Enhanced due diligence procedures should be clearly defined in policy and procedure.
Lenders need solutions. Without details, how do you complete disclosures, or check disclosures produced by your LOS? Without details, how do you determine what construction loan options to offer to your customers? It does not appear likely that the CFPB will provide binding guidance in the near future.
This fast-paced 2 hour session allows attendees to familiarize themselves with the requirements of the new regulation and develop an implementation plan that will require board involvement in revising policies and operational involvement in revising account opening procedures.