Compliance Blog

Jun 16, 2011

BSA Forms; OCC CMPs; Member Call-In

Written by Sarah Loats Zimmermann

Happy Thursday everyone! It's almost Friday!


New CTR and SAR forms.   Hat-tip to a fellow reader on this one - it seems we haven't mentioned the new forms yet. FinCEN has new CTR and SAR forms available on its website. The forms were issued March 2011 and can be used immediately. The forms note that previous editions of the forms will not be accepted after September 2011, so if you are still using the earlier versions, it might be time to think about switching over. There have been no substantive changes to the forms but the new versions will have to be used just the same after September.


OCC Civil Money Penalties. The OCC has announced it issued civil money penalties against J.P. Morgan Chase. The penalties related to the marketing and sale of credit protection products. The OCC asserts the marketing practices were unfair and deceptive and in violation of Section 5 of the Federal Trade Commission Act. I think this is noteworthy on two levels - 1) it attacks sales tactics of credit protection products, and 2) it uses the agency's unfair and deceptive authority to go after marketing practices it doesn't like. As we already know, the Federal Reserve issued proposed rules to increase disclosure requirements on credit protection products. The proposal may be tabled, but remember the GAO conducted a study on these products? And recommended to the CFPB that it review these products? I think this civil money penalty is just another sign that these products are being scrutinized by the regulators.


Member Call-In. NAFCU members, you can join us today for the member call-in. It is set for 4 pm EDT this afternoon. As always, the agenda includes a Washington regulatory and legislative update.