Compliance Blog

Posted by Anthony Demangone

I'm back from my diaper-related vacation.  Here are a few things that were rattling around in my in-box. 

• Flood.  A bank was hit with a $100,000 civil money penalty for flood-related violations.  In case you thought that was a typo, let me spell it out.  One.  Hundred.  Thousand.  Dollars.  Here's a link to the Order for Civil Money Penalty.  Read the first page of the order to see what this bank was doing.  Or not doing, as the case may be.   Note that the bank neither admits or denies that it did anything wrong.  But it will be writing a large check in any event.
• Scams.  The OTS has issued a foreclosure rescue scam brochure.  Access it here.  This is good information that you may want to "borrow" when creating newsletter material.  And the fact that it has been issued by OTS doesn't hurt.  I don't know if NCUA is planning on following suit.
• BSA. A credit union in Region I just let me in on an interesting tid-bit.  The credit union's BSA program noted that management would select the BSA Officer.  Once chosen, the credit union's BOD would approve the choice, and that was noted in the board meeting minutes.  Not good enough, said the examiner.  The examiner wanted the program to actually state the BSA officer(s) name.  Hmmm.  Why?  They wanted to know who the BSA Officer was when they looked at the policy/program.  Is that requirement expressly stated in any BSA regulation?  Not that I can find. 
• NCUA Board meeting.  NCUA has a pretty busy Board meeting today.  They make their board materials available on the morning of the meeting.  You usually can access those materials here.