Don't Ignore the Wiring
One of my hobbies away from compliance is the restoration and maintenance of a small collection of classic vehicles which I have purchased or inherited over the decades. One of those vehicles, which was passed down from my late grandfather, includes a 1951 Ford, which has always been maintained from an appearance and mechanical perspective. Only recently did I, however, notice a critical, yet potentially hazardous area that should have been addressed long before now...the wiring.
This same principle can often be applied to compliance, regardless of the size of the institution. Things look great on the exterior and seem to run great, however, read some of the regulatory enforcement actions. You may think how could such a bank, a bank that size, fail to comprehend and be cited for that.
Think on some of the potential wiring problems in your own institution.
- Are you as the BSA officer hearing of potential suspicious activity from your loan and deposit personnel? Is your BSA/AML monitoring software alerting you to suspicious activity?
- Are you certain the right of rescission is being properly handled?
- How about standard ATR documentation, is there a methodology?
- Are deposit accounts opening standards met for your particular state and as mandated by the SSA?
- Are you meeting the Safe Harbor standards for MLA compliance?
- Are you certain MSB's are being identified?
These areas and many other areas constitute "the wiring". We may have in place what we deem to be a good program and training. However, are we getting at what constitutes the spark that puts it all together, makes the engine run, and eliminates a potential breakdown or worse an electrical fire that takes out the entire vehicle?
There is a lot to the compliance program and being a compliance officer at any institution, but above all, "don't neglect the wiring".