Consumer Financial Protection Bureau

January 24, 2012

The Consumer Financial Protection Bureau (CFPB) is amending Regulation E, which implements the Electronic Fund Transfer Act, and the official interpretation to the regulation, which interprets the requirements of Regulation E.

Summary of the Rule

CFPB issues Final Remittance Rule (Amendment to Regulation E) is a post from: Bryant & Associates - Compliance is not an option

Federal Reserve Board

February 13, 2012

The Federal Reserve Board released the orders related to the previously announced monetary sanctions against five banking organizations for unsafe and unsound processes and practices in residential mortgage loan servicing and processing. The Board reached an agreement in principle with these organizations for monetary sanctions totaling $766.5 million on February 9, 2012.

FRB releases orders related to the previously announced monetary sanctions against five banking organizations is a post from: Bryant & Associates - Compliance is not an option

Federal Financial Institutions Examination Council

January 2012

On June 28, 2011, the Federal Financial Institutions Examination Council (FFIEC) issued a supplement to the Authentication in an Internet Banking Environment guidance, issued in October 2005.  The purpose of the supplement was to reinforce the risk-management framework described in the original guidance and update the FFIEC member agencies’ supervisory expectations regarding customer authentication, layered security, and other controls in the increasingly hostile online environment.

The continued growth of electronic banking and greater sophistication of the associated threats have increased risks for financial institutions and their customers.  Customers and financial institutions have experienced substantial losses from online account takeovers.  Effective security is essential for financial institutions to safeguard customer information, reduce fraud stemming from the theft of sensitive customer information, and promote the legal enforceability of financial institutions’ electronic agreements and transactions.

The supplement stresses the need for performing risk assessments, implementing effective strategies for mitigating identified risks, and raising customer awareness of potential risks, but does not endorse any specific technology for doing so.  The FFIEC member agencies will continue to work closely with financial institutions to promote security in electronic banking and have directed examiners to formally assess financial institutions under the enhanced expectations outlined in the supplement beginning in January 2012.

Supplement to Authentication in an Internet Banking Environment

FFIEC’s Regulatory Expectation on Supplemental Guidance on Internet Banking Authentication is a post from: Bryant & Associates - Compliance is not an option

Financial Crimes Enforcement Network (FinCEN)

February 7, 2012

The BSA defines the term “financial institution” to include, in part, a loan or finance company.  The term, however, can reasonably be construed to extend to any business entity that makes loans to or finances purchases on behalf of consumers and businesses. Non-bank residential mortgage lenders and originators, generally known as “mortgage companies” and “mortgage brokers” in the residential mortgage business sector, are a significant subset of the “loan or finance company” category.

FinCEN is issuing AML program and SAR filing regulations for residential mortgage lenders and originators as the first step in an incremental approach to implementation of regulations for the broad loan or finance company category of financial institutions.  Thus, the definition of “loan or finance company”  initially includes only these businesses, but is structured to permit the addition of other types of loan and finance related businesses and professions in future amendments.

Since 2006, FinCEN has issued numerous studies analyzing SARs reporting suspected mortgage fraud and money laundering that involved both banks and residential mortgage lenders and originators (see link below). The reports underscore the potential benefits of AML and SAR regulations for a variety of businesses in the primary and secondary residential mortgage markets. Residential mortgage lenders and originators are primary providers of mortgage finance – in most cases dealing directly with the consumer – and are in a unique position to assess and identify money laundering risks and fraud. Though not included in the definition of loan and finance companies, FinCEN has also proposed AML and SAR reporting rules for housing Government Sponsored Entities (GSEs).

FinCEN requires AML Program and SAR Filing for Non-Bank Mortgage Lenders and Originators (Mortgage Companies and Brokers)

FinCEN Proposes Anti-Money Laundering/Suspicious Activity Reporting Rules for Housing GSEs (Government Sponsored Entities)

Mortgage and Real Estate Fraud Studies

FinCEN requires AML Program and SAR Filing for Non-Bank Mortgage Lenders and Originators (Mortgage Companies and Brokers) is a post from: Bryant & Associates - Compliance is not an option

Financial Crimes Enforcement Network (FinCEN)

January 27, 2012

FinCEN Launches New Money Services Business (MSB) Registration Web site

For more information about the new MSB Registration Web site and to use the new Web site, please click on the following link: MSB Registration Web site.

If you have questions about the new MSB Registration Web site, please contact FinCEN’s Regulatory Helpline at 800-949-2732 for assistance. If you have questions about how to electronically file an RMSB, please call the E-Filing Help Desk at 866-346-9478.

FinCEN Launches New Money Services Business (MSB) Registration Web site is a post from: Bryant & Associates - Compliance is not an option

Financial Crimes Enforcement Network (FinCEN)

December 20, 2011

The deadline for financial institutions to utilize FinCEN’s new Currency Transaction Report (CTR) and Suspicious Activity Report (SAR) for reporting purposes will be extended to March 31, 2013.

Please see: FinCEN Extends Deadline for Adopting New CTR and SAR

FinCEN Extends Deadline for Adopting New CTR and SAR is a post from: Bryant & Associates - Compliance is not an option

Financial Crimes Enforcement Network (FinCEN)

December 19, 2011

FinCEN Releases Guidance to Assist Financial Institutions With Identifying and Reporting Account Takeover Activity

FinCEN Releases Guidance to Assist Financial Institutions With Identifying and Reporting Account Takeover Activity is a post from: Bryant & Associates - Compliance is not an option

Financial Crimes Enforcement Network (FinCEN)

December 15, 2011

Editor’s Note:  What’s worse is that the existence of the Suspicious Activity Report (SAR) was revealed to the very subject of the same SAR and then the bank employee extracted bribes to assist the subject of the SAR in thwarting any bank proceedings or federal criminal investigation!

FinCEN Assesses Civil Money Penalty for Suspicious Activity Report Disclosure

FinCEN issues a $25,000 Civil Money Penalty against a bank employee who unlawfully revealed the existence of a Suspicious Activity Report (SAR) is a post from: Bryant & Associates - Compliance is not an option

Transparency International

December 1, 2011

What is the Corruption Perceptions Index?

Transparency International’s Corruption Perceptions Index (CPI) is one of the best known tools in the fight against corruption. First launched in 1995, it has been widely credited with putting the issue of corruption on the international policy agenda. The CPI ranks almost 200 countries by their perceived levels of corruption, as determined by expert assessments and opinion surveys.

Watch the Video

Visualizing the CPI

Transparency International Releases 2011 Corruption Perceptions Index is a post from: Bryant & Associates - Compliance is not an option

Office of Foreign Assets Control (OFAC)

December 7, 2011

OFAC Releases New Specially Designated Nationals (SDN) and Blocked Persons List Search Tool is a post from: Bryant & Associates - Compliance is not an option