When it is necessary or desirable to perfect security interests in aircraft, engines, propellers or spare parts in the United States a lender must consider a multitude of issues. For many lenders and their counsel the process of recording instruments with the Federal Aviation Administration (the "FAA") and registering aircraft in the United States needlessly remains a mystery. The following is an explanation of the most critical issues a lender must address to ensure that documents submitted to the FAA will be accepted for recording.
We are looking to provide the Board of Directors with an annual report card on our BSA/AML program (with information such as how many CTRs; we filed how many SARs; and how many SARs were investigated and not filed etc.) Are there any templates out there for this type of report to give us a starting point?
Could you please tell me of a source for BSA training for our Board of Directors?
Acts of workplace violence that stem from violence domestic relationships seem to be more common than ever before. We employ about 150 people and I know of two employees that are in abusive relationships. One of these employee's husbands has threatened to kill her and everyone she works with if she ever leaves him. How can people stay in these relationships? I know so little about this issue and I'm the credit union's Security Officer.
Does the written Security Program for a bank have to be approved by the Board of Directors? If so, do subsequent updates also have to be approved by the board? This is not to be confused with the regular reports to the board about the status of the bank relating to the program.
Would there be a fine to a financial institution for not filing a SAR on an employee for check kiting?
Is there a certification course available for financial institution security officers?
When it comes to SAR filing, who should make the final decision to file? The President, Board of Directors or the BSA officer?
We are putting together our BSA training schedule. What courses are required annually and what can be done every other year or on an alternative schedule?