|Event Date||Wed Apr 15 EDT (almost 2 years ago)|
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.
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.
Who Should Attend?
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.
Managing Director, Treliant Risk Advisors