Thursday, October 19, 2017

Controls over Employee and Officer T&E Expenses

Posted by Sharon August 16, 2017 11:05am
Sample Image Photo Credit: Galina Peshkova

Over the past year, we have seen the regulators more closely scrutinizing banks’ expenditures as they relate to Officer’s Travel and Entertainment (“T&E”).  Depending upon the nature of the bank’s business, asset size, and officer structure, controls in this area might vary greatly. However, one thing for sure is that we are moving towards the fact that institutions should have an adequate process in place to address their specific risks...

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Is Regulation CC Put on the Back Burner?

Posted by Sharon August 15, 2017 4:36pm
Sample Image Photo Credit: prykhodov

Regulation CC was enacted in 1987 in order to standardize hold periods on deposits made to banks and to regulate a bank’s use of deposit holds. There have been many changes throughout the years, but one in particular is that all checks are considered local and clear on a much timelier basis than in earlier years. One thing that remains unchanged is Regulation CC applies to both personal customers and commercial customers...

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Sample Image Photo Credit: nationalmortgagenews.com/

So I attended the NJ Bankers Compliance University in June 2014 and wanted to share some of the information that I came away with to try to assist community banks in knowing where the regulators are going to focus their attention. Please note that these are in no particular...

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Some tips and tricks for dealing with Regulatory Examinations

Posted by Sharon February 13, 2015 11:29am
Sample Image Photo Credit: blog.regulatorycompliance.com

  • Designate a central point of contact to coordinate examination matters and deliver requested information – the “Examination Manager.”
  • The examination manager is the chief liaison with the Examiner in Charge (“EIC”) and the examination team, and will resolve any examination issues while examiners are on-site.
....

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Updated Regulation E Booklet from the OCC!

Posted by Sharon February 13, 2015 11:15am
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On August 28, 2014, the Office of the Comptroller of the Currency issued the “Electronic Fund Transfer Act” booklet of the Comptroller's Handbook. This revised booklet replaces a similarly titled booklet issued in October 2011. This updated booklet provides updated guidance to examiners and bankers relevant to recent changes made to Regulation E (12 CFR 1005) regarding remittance transfers. These rules are promulgated by the CFPB and stem from the 2010 Dodd-Frank financial reform law.

Community Banks must be aware that the...

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Is Flood Disaster Still on the Heat Map?

Posted by Sharon February 13, 2015 11:07am
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You bet it is!!!! With all of the training banks have paid for and had their employees attend, why are banks still getting flood violations?

There are many ways to violate the flood hazard requirements: you could fail to timely or properly complete the Standard Flood Hazard Determination Form on covered loans, not give the borrower the notice of flood hazards within the right timeframe...

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Have You Implemented Your Plan yet?

Posted by Sharon February 13, 2015 11:03am
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Not only do financial institutions have to be in compliance with the new mortgage rules implemented as a result of the Dodd Frank Act, but they have to have a PLAN in place FIRST, to implement the changes.

During initial examinations for compliance with the new regulations, FDIC examiners will expect institutions to be familiar with the mortgage rules' requirements and have a plan for implementing the requirements. The FDIC notes that implementation plans should contain .

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FDIC Consumer Newsletter

Posted by Sharon February 13, 2015 10:58am
Sample Image Photo Credit: FDIC

The winter issue of the FDIC Consumer News features tips on choosing and using credit cards. Other topics include: ways to protect personal information, money and banking tips for the tax season, testing one's deposit insurance IQ, and preparing for rising home equity line payments.

Credit cards are an important part of many consumers' financial lives, but it helps to understand how to make the most of these products and avoid...

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More Flood Insurance Changes...

Posted by Sharon February 12, 2015 9:36am
Sample Image Photo Credit:

On July 6, 2012, the Biggert-Waters Flood Insurance Reform Act of 2012 (“B-W Act”) became law. The B-W Act made several substantial changes to the flood insurance rules, many of which affected lenders. While most provisions were effective only after implementing regulations are written, two major provisions of the B-W Act, one regarding the force placement...

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Following on the heels of the Supreme Court’s June 26, 2013 decision in United States v. Windsor, Director Richard Cordray of the CFPB issued a memorandum setting forth guidance on equal treatment for legally married same-sex couples.

He stated, “It is the Bureau’s policy, to the extent...

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The Bureau of Consumer Financial Protection (“Bureau”) issued a final rule amending the regulatory text and official interpretations for Regulation Z, which implements the Truth in Lending Act (“TILA”). The Bureau is required to calculate annually the dollar amounts for several provisions in Regulation Z; this final rule reviews the dollar amounts for provisions implementing amendments to TILA under the Credit Card Accountability Responsibility and Disclosure Act of 2009 (“CARD Act”), the Home Ownership...

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ABA Survey on Impact of Dodd Frank Compliance

Posted by Sharon January 19, 2015 4:34pm
Sample Image Photo Credit: ABA

In case you were wondering about the impact of the implementation of compliance with the Dodd Frank Act, check out this survey taken by the ABA last summer. I have wondered what the effects would be and this survey has confirmed my earlier

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ABA Mortgage Origination Deskbook

Posted by Sharon January 19, 2015 4:26pm
Sample Image Photo Credit: ABA

ABA and law firm BuckleySandler released “The New CFPB Mortgage Origination Rules Deskbook,” a free and comprehensive reference guide to help bankers understand and comply with the CFPB’s rules when originating loans.

The ABA members-only deskbook — available in a printable electronic format — consolidates all available CFPB compliance guidance. In addition to the rule text and official commentary, the deskbook encompasses CFPB interpretive rules...

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Who handles Your Dormant Accounts?

Posted by Sharon November 26, 2014 2:03pm
Sample Image Photo Credit: hin255

Do your tellers have access to determine which accounts at your Bank have become dormant? Or is your dormant account function housed in your back-office Operations Department? I had a conversation with a colleague of mine the other day that sparked me to write on this topic. They told me that they still had a passbook savings account and that they hadn’t updated their passbook in the branch for several years. This prompted me to...

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How do you charge Early Withdrawal Fees on Time Deposits?

Posted by Sharon December 16, 2013 4:25pm
Sample Image Photo Credit: ctoocheck

One thing I have suggested to bankers in a low interest rate environment is to review their early withdrawal penalty on time deposits. Most institutions calculate the early withdrawal penalty as a number of days of interest.

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Do you still offer NOW Accounts?

Posted by Sharon October 8, 2013 12:54pm
Sample Image Photo Credit: hin255

A demand deposit account is a checking account. Most demand deposit accounts (“DDA”) allows the customer to withdraw money from their account without advance notice, but the term also includes accounts that require six days or less of advance notice.

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Policy Changes Required – Do you Wait until Annual Approval?

Posted by Sharon September 19, 2013 5:23pm
Sample Image Photo Credit: 4seasons

Let’s say a team of BSA internal auditors come in and audit your Bank. At the conclusion of the audit, an internal audit report is issued to the Bank’s audit committee with a recommendation for changes to the BSA policy. Management indicates in their response to the audit report that they agree with the recommended changes and will update the policy accordingly. Now come the questions..

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ACAMS to provide Free Webinar

Posted by Sharon August 23, 2013 11:23am
Sample Image Photo Credit: free digital phts

The Association of Certified Anti-Money Laundering Specialists (“ACAMS”) is an association that provides training and certification, runs conferences and disseminates information on detection and prevention of money laundering. ACAMS was founded in 2001 and has grown immensely since then. ACAMS is now the largest international membership organization dedicated to enhancing the knowledge and expertise of Anti-Money Laundering (“AML”) and financial crime detection and prevention professionals.

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ACBB Changes its Name

Posted by Sharon August 23, 2013 10:46am
Sample Image Photo Credit: sixninepixels

In the New Jersey Banker’s Bulletin dated August 21, 2013, there is an article in regards to ACBB changing its name from Atlantic “Central” Banker’s Bank to Atlantic “Community” Banker’s Bank.

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Who Do You Give Cash to?

Posted by Sharon August 14, 2013 3:39pm
Sample Image Photo Credit: kaifreedom

Many historical internal frauds stem from teller theft or Customer Representative personnel theft. Unfortunately branch personnel can become intuitive in figuring out ways to redirect funds from the cash box or from a customer. This is a concern that keeps Senior Management and even Board members often worried.

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ABA Briefing to Help Banks Address Cyber-security Threats

Posted by Sharon August 14, 2013 3:30pm
Sample Image Photo Credit: scottchan

Computer security (Also known as cyber-security or IT Security) is information security as applied to computers and networks. The field covers all the processes and mechanisms by which computer-based equipment, information and services are protected from unintended or unauthorized access, change or destruction. Computer security also includes protection from unplanned events and natural disasters.

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Sample Image Photo Credit: hin255

On June 13, 2013, the OCC issued a booklet titled, “A Common Sense Approach to Community Banking”. The booklet was previously distributed to national banks and federally chartered thrifts, however, is now available on the OCC’s Website.

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Sample Image Photo Credit: hin255

Safe Deposit Box contents are not insured by most Banks and are not insured by the FDIC. If you have signed a safe deposit box contract with the Bank, you most likely have to read directly on the contract that the contents of your box are not insured.

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FDIC Can Review New Products

Posted by Sharon July 31, 2013 12:09pm
Sample Image Photo Credit: adamr

Last month, I attended an ABA Regulatory Compliance teleconference. Towards the end of the conference, an FDIC representative said was that if a Bank has a new product that they are planning on offering to customers, the Bank can call the FDIC and they will personally send someone from the FDIC out to the Bank to review all aspects of the new product prior to...

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Let’s Talk About Overdrafts!

Posted by Sharon July 25, 2013 4:57pm
Sample Image Photo Credit: scottchan

An overdraft occurs when money is withdrawn from a bank account and the available balance goes below zero. In this situation, the account is said to be "overdrawn". Overdrafts are a leading compliance concern due to lost revenue, heightened compliance risk, and threats of UDAAP violations.

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Sample Image Photo Credit: Stuart Miles

A majority of our banking transactions are now handled electronically. In banking, this can cause an unwanted customer service issue when a customer wants to "stop payment" on an electronic item, especially on a recurring debit.

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CFPB Stands Up Against Poor Debt Collection Practices

Posted by Sharon July 12, 2013 11:25am
Sample Image Photo Credit: hin255

On July 10, 2013, the CFPB notified all companies under its jurisdiction that they will be held accountable for unlawful conduct in collecting a consumer’s debts and issued Bulletin’s on Debt Collection.

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Don’t Forget the Small Stuff

Posted by Sharon July 11, 2013 11:12am
Sample Image Photo Credit: Suat Eman

With the current “eye of the regulatory storm” being mostly focused on asset quality, IRR and problem loans, you might be forgetting to check up on “not so blatantly obvious” potential for regulatory scrutiny.

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Double Endorsed Checks: What is the Risk?

Posted by Sharon July 3, 2013 2:38pm
Sample Image Photo Credit: muresan113

There are risks involved in the deposit of a double (or triple) endorsed check. The biggest risk being forgery. Even if the Bank knows and trusts the endorsement of the bank's depositor (the second endorser), generally they cannot verify the authenticity of the first endorsement. If the first endorsement is a forgery, or unauthorized, the depositary bank will be liable on their warranty that each of the prior endorsements was genuine and authorized, and that warranty extends for between one year and three years under the Uniform Commercial Code.

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Social Media – Will the Regulators Do Spot Checks?

Posted by Sharon June 25, 2013 12:23pm
Sample Image Photo Credit: ctoocheck

found out today that the Financial Industry Regulatory Authority (“FINRA”) is doing social-media compliance spot checks on some of its member firms. In a notice posted Monday on FINRA’s website, the regulator said it wants broker-dealers to identify the sites used by a firm, as well as all individuals who post or update the firm’s content on social-media sites.

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Controls Worth Sharing – Did you know?

Posted by Sharon June 25, 2013 11:49am
Sample Image Photo Credit: jscreationzs

Working with the internal audit function in many community banks over the years, I have come across some really good controls and thought this would be a great opportunity to share them with you.

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Solutions to Reducing Dormant Accounts at Your Institution

Posted by Sharon February 8, 2013 12:03pm
Sample Image Photo Credit: Kittikun

Unclaimed property is governed by state laws. Although each state may be a little different in its requirements, all will require you to escheat unclaimed property to the state after a certain length of time where you have not had contact with your customer.

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Regulation E Foreign Remittance Rules

Posted by Sharon January 18, 2013 5:17pm
Sample Image Photo Credit: morguefile.com

Regulation E Foreign Remittance Rules go into effect February 7, 2013 as promulgated by the CFPB (Consumer Financial Protection Bureau). These rules can be found in Subpart B of Regulation E (12CFR Chapter X part 1005). There are a lot of related tools located on the CFPB’s website that can also give you more information. You can click this link. The CFPB has also posted a free webinar video that you can watch that will give you all of the rules and help you determine if you will be subject to these rules.

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Expiration of Unlimited Deposit Insurance for NIBTAs

Posted by Sharon December 31, 1969 7:00pm
Sample Image Photo Credit: vichie81

I realize this article is coming out a little late, however, for those banks that are not yet prepared, you still have time to show the regulators that you have prepared for the December 31, 2012 expiration. While there is still a small chance that the regulatory agencies will choose to extend the Insurance program as it pertains to Non-Interest Bearing Transaction Accounts (NIBTA), we are getting closer to the December 31, 2012 expiration date with no word on any extension.

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Regulation O – 5 Easy ways to avoid violations

Posted by Sharon July 12, 2012 9:50am
Sample Image Photo Credit: freedigitalphotos.net

Regulation O covers transactions between the financial institution and their insiders (directors, executive officers, and related interests). Regulation O limits the extensions of credit to these insiders in a number of ways.

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Sharon Geiger

Quality Control Specialist

Sharon Geiger, Quality Control Specialist Sharon has 27 years banking experience, 21 of which have been involved in internal audit. She has extensive knowledge of all aspects of the banking industry, with a particular emphasis on regulatory compliance and identifying risks and controls. As QCR Specialist, she performs Quality Control Reviews to ensure all workpapers and reports are completed in compliance with the firm's standards.



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Controls over Employee and Officer T&E Expenses
Is Regulation CC Put on the Back Burner?
Top Compliance Topics Discussed at the NJ Bankers Compliance University
Some tips and tricks for dealing with Regulatory Examinations
Updated Regulation E Booklet from the OCC!
Is Flood Disaster Still on the Heat Map?
Have You Implemented Your Plan yet?
FDIC Consumer Newsletter
More Flood Insurance Changes...
Same Sex Married Couples - Ensuring Equal Treatment – Announcement from Consumer Financial Protection Bureau
Truth in Lending (Regulation Z) Annual Threshold Adjustments (CARD ACT, HOEPA and ATR/QM)
ABA Survey on Impact of Dodd Frank Compliance
ABA Mortgage Origination Deskbook
Who handles Your Dormant Accounts?
How do you charge Early Withdrawal Fees on Time Deposits?
Do you still offer NOW Accounts?
Policy Changes Required – Do you Wait until Annual Approval?
ACAMS to provide Free Webinar
ACBB Changes its Name
Who Do You Give Cash to?
ABA Briefing to Help Banks Address Cyber-security Threats
The OCC Issues Booklet: “A Common Sense Approach to Community Banking”
Safe Deposit Box Contents are not insured – But They COULD Be!
FDIC Can Review New Products
Let’s Talk About Overdrafts!
Regulation E and NACHA Rules: When you Want to Stop Payment on a Recurring Debit
CFPB Stands Up Against Poor Debt Collection Practices
Don’t Forget the Small Stuff
Double Endorsed Checks: What is the Risk?
Social Media – Will the Regulators Do Spot Checks?
Controls Worth Sharing – Did you know?
Solutions to Reducing Dormant Accounts at Your Institution
Regulation E Foreign Remittance Rules
Expiration of Unlimited Deposit Insurance for NIBTAs
Regulation O – 5 Easy ways to avoid violations