Compliance Blog

Posted by Anthony Demangone

Happy Tuesday, everyone.

Modifications.  The folks at Bankersonline.com give us a great reminder.  When doing a loan modification to a real estate loan, do not forget about flood insurance requirements. 

CTRs. Roughly 18 months ago, FinCEN loosened CTR exemption requirements.  Yesterday, FinCEN released a report that discusses the impact of those changes.  The following two paragraphs came from the executive summary of the report. Emphasis is added.

The positive effects of those changes are most clearly reflected in the number and type of DOEP filings. Overall, FinCEN found that DOEP filings fell 44 percent to the lowest levels ever. Since the rule made DOEP filings unnecessary when the subject is a bank, government agency, or governmental authority, those filings dropped nearly 75 percent in 2009. Those filings should eventually fall to zero, and measuring them is a good indication of the rule’s effectiveness...

The adoption of the amended CTR exemption rules also appears to have helped reduce the overall volume of CTR filings. While economic conditions may account for some of this decrease, FinCEN found that the total number of CTRs filed in 2009 declined nearly 12 percent compared with the previous year, dropping from 15.5 million to 13.7 million. This trend is particularly important as CTRs account for almost 90 percent of financial institutions’ annual BSA filings. This decrease was seen among the smallest (13.6 percent year-over-year reduction) and the largest
institutions (20.3 percent reduction). As a result, it appears likely that fewer CTR filings are being made on transactions of limited or no use to law enforcement, while the higher value CTRs that remain are becoming easier to identify.