Compliance Blog

Posted by Anthony Demangone

Here are some items of interest.  Enjoy!

BSA.  Remember when we learned that FinCEN was streamlining its regulations into a new Chapter X? Well, the changes are now effective. 

As noted in the final rule published in the Federal Register on October 26, 2010, the reorganization streamlines the BSA regulations into general and industry-specific Parts, making the regulatory obligations clearer in their structure and more accessible to affected financial institutions. Chapter X helps a financial institution identify its obligations under the BSA in a more organized and understandable manner. Prior to March 1, 2011, FinCEN’s regulations were included in the CFR as Part 103 in Chapter I under “Title 31, Money and Finance: Treasury.”

So, nothing has changed.  Things have just been organized to make them clear and more accessible.  That's much akin to reorganizing one's closet.  The clothes don't change.  You just arrange them in a way that makes more sense.  But here's the rub.  Let's say your wife (or your husband) reorganizes your closet for you.  Good luck finding anything.

Also, note that FinCEN recently issued guidance related to events in Egypt and Libya. 

Interchange.  A new study shows that the Fed's interchange regulation will harm consumers.   (Hat tip to the ABA. That's right.  The ABA.)

FDIC.  Kudos to the FDIC for this guidance document, which outlines what rights banks have during their examinations.