BSA CMP; CFPB Budget
Posted by Anthony Demangone
FinCEN and the OCC have taken action against Zion First National Bank of Utah.  The total fine?  $8 million. Â
According to the OCC:
The OCC commenced an investigation into the BankâÂÂs former foreign correspondent business and identified deficiencies in its Bank Secrecy Act and anti-money laundering controls, which resulted in violations of law. In particular, the Bank had developed a remote deposit capture product that enabled customers to deposit imaged items electronically from remote locations and marketed the product to high risk customers in 2006 and 2007 without sufficient regard to BSA/AML compliance implications. The Bank exited the foreign correspondent line of business in early 2008, promptly conducted a voluntary look back, and reported suspicious activity.
If you read the FFIEC BSA Manual, you'll see a general theme, and this enforcement action is a great reminder of that theme. Â Regulators really don't care what you do or who you serve (within reason), they rather focus on the following. Understand what you do and who you do it with. Â Understand how that all affects your BSA risk. Â And then build in the necessary internal controls to adequately manage that risk. Â
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It is budget season in Washington, D.C.  Elizabeth Warren, who is heading up implementation efforts at the CFPB, blogged about the CFPB's budget.   Hey, they get an kudos for transparency.  But boy, oh boy, they are planning to hire a bunch of people and increase their budget by more than 100%. Â
For comparison purposes:
NCUA's 2011 budget:$225.4 million.
CFPB's 2011 budget: $142.8 million  (The agency doesn't officially start "regulating" until July.
But in 2012, the CFPB's budget looks to jump to $329 million.Â
Consumer issues, my friends, will be getting much more attention.Â
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