BSA Manual Change Overview Document
Posted by Anthony Demangone
Recently, the FFIEC released the 2010 version of its BSA/AML Examination Manual.   Here are some thoughts:
- It is 439 pages long.  Luckily, they did provide a rough road map by inserting "2010" in the table of contents after any section with changes.
- The agencies also included this transmittal letter, which provides a few details on the major changes to the manual. Â
- The new manual will force you to review your current BSA/AML policy and program against the changes to the manual. Â You may have to add some internal controls based on the changes. Â And remember - the board has to approve your credit union's BSA/AML program changes.Â
- The Federal Reserve Board issued Supervision and Regulation Letter SR 10-9 to introduce the manual to its regulated entities.  The Fed instructed its examiners to begin using the 2010 manual on May 1.  Of this year.  And the old 2007 manual is kaput.  The new one completely supersedes it.  And this snippet from SR 10-9 really made me chuckle:Â
As with prior versions of the FFIEC BSA/AML Examination Manual, the 2010 revised manual does not set new standards; instead, it is a compilation of existing regulatory requirements, supervisory expectations, and sound practices in the BSA/AML area. (Dumbfounded emphasis added.) SR 10-9.
My sarcastic take on that statement is this (read in the voice of Stewie of Family Guy): Really? Â Nothing new? Really? Â And the prior versions did not set new standards? Â Really?
There is new material here, in my humble opinion.  There is a greater emphasis on the role of your board of directors.  There is a ton of new information regarding "electronic cash."  There are new expectations, for example, on how you measure and manage the risk of offering stored value cards.  There is a new section that talks about how you can structure your organization to manage BSA/AML risk.  There's an enhanced section on independent testing.  In short, the manual does have new stuff. And if examiners are going to use it to examine you, that creates a new standard in my book.
NAFCU Members: Because I love you, I created a 7 page document (NAFCU member log in needed) that provides an overview of the changes found within the 2010 manual. Â
Mark your calendar. Â On July 14, I'll take part in a NAFCU webcast that will provide a general overview of the changes to the manual. Â We'll address Reg Z issues as well. Â But it may be good to invite other BSA team players (or have them watch the archive) so that you're all on the same page. Â