BKD Financial Services Webinar Series
For additional information or to register for these informative one-hour webinars, please see our Financial Services webinars page.
Qualified, experienced BKD client service professionals write the contents of these articles. We urge you to carefully consider all of the facts and circumstances of your situation before applying specific information in our articles. Consult your BKD advisor before acting on any matter covered in these articles.
|
March 2009
Changes to CTR Exemption RequirementsEffective January 5, 2009 On December 4, 2008, the Financial Crimes Enforcement Network (FinCEN) released final rules amending the Bank Secrecy Act (BSA). These changes, which went into effect January 5, 2009, make significant changes to the Currency Transaction Report (CTR) exemption process. Fortunately, these changes should reduce some of the regulatory burden of CTR reporting. Please click here for additional information.
Revised CRA Questions and AnswersEffective January 6, 2009
On January 6, 2009, federal financial institution regulatory agencies published Questions and Answers Regarding Community Reinvestments (“Q&As”). They adopted nine new questions and answers and made significant changes to 14 existing questions and answers. While the revised Q&As are generally clarifying in nature, they do establish one change that will assist “intermediate-small banks” with their community development test. Previously, if a loan met the qualifications of a “small business loan” or “small farm loan,” or would require reporting pursuant to the Home Mortgage Disclosure Act (HMDA), it was not eligible for treatment as a community development loan. This limitation applied even to those banks that were not required to report small business or small farm loans, as well as those financial institutions that were not required to report HMDA data. As of the effective date of this Q&A, intermediate small banks that are not required to report HMDA, small business or small farm loans, may have such loans considered as community development loans, provided they meet the regulatory definition of “community development.” The new Q&As are effective January 6, 2009, and supersede all previously published interagency Q&As.
To access the revised Q&As, you may click on the following link: http://www.occ.treas.gov/fr/fedregister/74fr498.pdf
FFIEC Issues Guidance on Remote Deposit CaptureIssued January 14, 2009
On January 14, 2009, the Federal Financial Institutions Examination Council (FFIEC) issued guidance regarding the risk management practices of financial institutions offering Remote Deposit Capture (RDC). The guidance suggests financial institutions should conduct a risk assessment of its RDC system that evaluates the legal, compliance, reputation and operational risks associated with the system. The guidance also encourages comprehensive risk management controls, including customer selectivity training, vendor due diligence, well-constructed contracts and agreements and proper business continuity planning.
To access the FFIEC guidance, you may click on the following link: http://www.ffiec.gov/pdf/pr011409_rdc_guidance.pdf
|
