BSA/AML for Lenders
The BSA/AML Interagency Exam manual addresses lending within its coverage and a key examiner focus is the following:
“Assess the adequacy of the bank’s systems to manage the risks associated with lending activities, and management’s ability to implement effective due diligence, monitoring, and reporting systems.”
Lending activities include, but are not limited to, residential and commercial real estate, secured commercial loans, credit cards, consumer, commercial, and agricultural loans. Lending activities can include multiple parties (e.g., guarantors, signatories, principals, or loan participants). The new 5th Pillar CDD rule takes particular aim at commercial lending and turns implied guidance into express regulations. The BSA considers all loans, whether they be residential, commercial, consumer, etc to be “accounts” and subject to the CIP requirements and applicable to SAR and CTR reporting.
This two-hour program will assist your bank in determining whether your BSA Compliance Program adequately includes controls, such as training, policies and procedures, monitoring, etc for loan products in addition to deposit products. A number of the BSA examiners “grew up” in the Safety and Soundness world and are particularly adept in identifying BSA-related deficiencies in the commercial lending area and therefore find lax controls in the commercial lending area because some commercial lenders believe that the BSA is a compliance regulation and doesn’t apply to commercial loans. Additionally, many banks still have BSA training programs primarily tailored to consumer deposit accounts and do not provide sufficient training for lending-related situations.
This program will also teach you how to conduct due diligence on related account parties (i.e., guarantors, signatories, or principals) as well as beneficial owners.
Upon completion of the program participants have a much better understanding of the following:
- Commercial and residential mortgage loan money laundering schemes identified by FinCEN through a 10-year study of SARs;
- Lending Red Flags, including those addressed in the BSA Exam Manual and many more
- Customer Due Diligence (CDD) and, Enhanced Due Diligence (EDD) expectations regarding loans;
- Beneficial Ownership identification and verification requirements for Legal Entity Customers;
- How to develop customer risk profiles and conduct ongoing risk-based monitoring for loan products;
- SAR and CTR reporting requirements; and
- Portions of your BSA Policy/Program that need to address lending.
The program is designed for Commercial Loan Officers, Commercial Operations Personnel, BSA Officers, Compliance Officers, Auditors, and those responsible for either overseeing BSA in general or those within the lending business units with BSA responsibilities.
Don L. Blaine is the Senior Training Consultant for Compliance Resource, LLC, a source of compliance assistance for financial institutions. Don has over 30 years of experience in regulatory compliance for the banking industry with banks ranging in size from community banks to money center banks. He is considered a subject matter expert in many of the consumer affairs laws and regulations and will be primarily specializing in training activities that will encompass the Bank Secrecy Act/Anti-Money Laundering laws and regulations as well as many of the laws and regulations related to deposit compliance. His prior roles have included: Chief Compliance Officer, Senior Compliance Regulatory Examiner, Compliance Audit Manager, and business unit compliance manager. He has taught at the ABA’s National Compliance School and has also served as an instructor on BSA and compliance topics at various programs offered by state banking associations. Prior to joining Compliance Resource, LLC, Don served as a consultant to numerous banks in areas ranging from BSA to lending and deposit compliance. He has attained Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) certifications.
Institute of Certified Bankers: Visit http://www.icbmembers.org/login.aspx for instructions regarding self-reporting. Estimated credits: 2.5 CE Credits
- Live Webinar which includes 5 Day On-Demand - $265
- Six Month On-Demand – $295
- CD-ROM (Includes Six Month On-Demand) – $345
- Live plus Six Month On-Demand – $365
- Premier (Includes all options) – $395
- Additional Locations – $75
Online: Click here.
Phone: Call Total Training Solutions at (800) 831-0678
Register online up to day of event. Earlier registration allows time to check your computer for an optimal experience.