Compliance Blog

Posted by Anthony Demangone

In late February, GAO issued a report titled "BANK SECRECY ACT Suspicious Activity Report Use Is Increasing, but FinCEN Needs to Further Develop and Document Its Form Revision Process.  That is a report that only a compliance officer could love.

Here's a link to the report.

Your first thought may be: Ahhhh! It is 57 pages long!  But here's a trick about reading GAO reports.  You don't need to read the whole thing to see what GAO has to say.  They provide a sort of "cheat sheet" for your consumption.  First, there's often a cover letter that is written to Congressman(men) who requested the report.  Then, there's an executive summary or "results in brief."  Those two items take up pages 1 - 7 of this report.  (Pages 5-11 of the .pdf.)

Here's another great aspect of GAO reports.  They do a bang-up job of writing term papers.  If you do board training or staff training, their overview of the BSA and SAR process.  Feel free to cut and paste use the report as inspiration for your own work.

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FinCEN recently released guidance to warn financial institutions on the possible need to file SARs on Loan Modification/Foreclosure Rescue Scams.  It never fails to amaze me how scumbags always rise to the surface during a crisis.  FinCEn reminds us that scam artists may attempt to target your members or use your accounts to rip off consumers during this time of financial confusion.  FinCEN gives examples of possible indicators of such scams within the guidance.  This is a must read.  It may not be a bad idea to give an overview of this to your frontline staff.  That way, if they hear members talking about some of the indicators, they can talk to the member about the existance of such scams. 

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Attention E-Filers. BSA E-Filing will transition to Adobe forms.

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Most NAFCU members don't know many of the people who work at the association.  One of those persons was Robin Johnston.  NAFCU was truly blessed to have Robin on staff.  She was in charge of The Federal Credit Union, NAFCU's magazine.  She always carved off some space for a compliance-related article within each issue.  And she always bent over backwards to work with us when we invariably missed her deadlines.  Sadly, Robin recently passed away.  NAFCU wrote a wonderful article about Robin, and you can access it here.  Robin was the ultimate coworker.  Funny.  Conscientious.  Talented.  Respectful.  And boy, did she love credit unions.  We will miss her dearly.