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Beneficial Ownership

Your Customer Due Diligence Program – Time to Fill in the Gaps: Part Six The newest piece to your customer due diligence program. You should have things in full swing now as the deadline is just around the corner: May 11, 2018. Let’s dive right in to highlight the key …

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Standard Due Diligence – Part 5 in a Series

Your Customer Due Diligence Program – Time to Fill in the Gaps: Part Five So far in this series we’ve addressed customer due diligence policies and procedures and their importance, CIP, and the customer risk profile – all components of your customer due diligence program. Now, we’ll spend a brief …

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Customer Identification Program Requirements – Your Customer Due Diligence Program – Part Three

Why write about Customer Identification Program (CIP) requirements? Honestly, not a lot has changed to this area for quite some time. Very true, indeed. However, it never hurts to address a few questions to ensure that no gaps may exist. And, with the upcoming beneficial ownership rule effective on May …

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Policies and Procedures – Your Customer Due Diligence Program – Part 2

Often times when we hear “policies and procedures,” does this mental picture comes to mind: various Charlie Brown cartoons with the teacher saying “wah wa-wah wah wa-wah” and so on? All joking aside, part two of this series is about your policies and procedures in relation to your customer due …

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Your Customer Due Diligence Program – Time to Fill in the Gaps

With the beneficial ownership rule deadline right around the corner, we’ll spend some time camping on Customer Due Diligence Program elements. We’ve all been required to know our customers for quite some time now, and that we need to have a good understanding of how customers are going to act, …

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Here We Come Compliancing

“Here We Come A-wassailing” (or Here We Come A-Caroling) is an English traditional Christmas carol and New Year song. The wassail bowl itself was a hearty combination of hot ale or beer, apples, spices, and mead, just alcoholic enough to warm tingling toes and fingers of the singers. Compliance professionals …

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2017: Taking a Momentary Look Back

“Don’t stumble over something behind you.” – Seneca, Roman Stoic philosopher Wait! Not the kind of look back as would be required by a regulator for noncompliance or a documented deficiency to a compliance program. Often, we hear that looking back doesn’t help us to move forward. While this may …

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Risk Assessment – What, Why, When

“Lack of direction, not lack of time, is the problem. We all have twenty-four-hour days.” Zig Ziglar, Motivational Teacher and Trainer Risk. It’s inherent in the business of lending money. Financial institutions face risks associated with new products and services, operational failures, and procedures and practices to meet regulatory guidance. …

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Production Incentives – Incenting Unwanted Problems?

Financial institutions sometimes choose to implement incentive programs to achieve business objectives. When properly implemented and monitored, reasonable incentives can benefit consumers and the financial marketplace. In November 2016, the Consumer Financial Protection Bureau (CFPB) published “CFPB Compliance Bulletin 2016-03 (Bulletin)” to share the CFPB’s supervisory and enforcement experience in …

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