Now Onboarding All Rows and All Passengers for Flight WACHA 2014
|
|
- Shanna Willis
- 6 years ago
- Views:
Transcription
1 Now Onboarding All Rows and All Passengers for Flight WACHA 2014 Regulatory, Compliance, and On Boarding Best Practices Brent Siegel, CSOP, CRFS, MBA, Argos Risk Wendy Wishon, AAP, NCP, EPCOR March 18, 2014
2 a true story SO CUTE! SO INNOCENT! 9 year old boy
3
4
5
6 HOW DID THIS HAPPEN? WHERE DID THE ONBOARDING PROCESS FAIL?
7 AGENDA
8 Improving the Onboarding Process 2014EPCOR EPCOR.. All All rights rights reserved.
9 FFIEC Retail Payment Examination Handbook EPCOR.. All All rights reserved. 9
10 OCC ACH Risk Management Guidance EPCOR. All rights reserved.
11 IRS EPCOR. All rights reserved.
12 OFAC EPCOR.. All All rights reserved. 12
13 BSA and OFAC EPCOR.. All All rights reserved. 13
14 Board Strategic Objectives Establish business strategy and risk parameters Oversee management s implementation of the program Develop strategic objectives, limitations, and overall risk appetite Approve ACH policies 2014 EPCOR. All rights reserved. 14
15 ACH Policy Territory Territory SEC Codes SEC Codes Originator Originator Types Types Collateral, Collateral, Funding Pre-Funding Approval Approval Requirements Requirements Exposure Exposure Limits Limits ACH Risk Management Committee Responsibilities Documentation Monitoring Procedures OFAC 2014 EPCOR. All rights reserved.
16 Due Diligence Underwriting Standards Formal review of all Originators Process to match level of risk 2014 EPCOR. All rights reserved.
17 Underwriting Underwriting Standards Define desirable, prohibited, and restricted originators Require a background check of the originator Require evaluation of the originator's creditworthiness Outline the type and timing of financial information to be provided by the originator 2014 EPCOR. All rights reserved.
18 Underwriting Underwriting Standards Require review of the originator's sales history Summarize documentation requirements List permissible Standard Entry Class (SEC) types Provide authorization procedures for approved originators 2014 EPCOR. All rights reserved.
19 Underwriting Underwriting Standards Provide guidelines for setting exposure limits, including requirements for pre-funding or collateral requirements Establish over limit monitoring and approval Outline originator account termination procedures Allow the institution to audit originators' ACH processes 2014 EPCOR. All rights reserved.
20 Unbiased Originator Info 2014 EPCOR. All rights Copyright 2014 EPCOR Allreserved. rights reserved. 20
21 Dun & Bradstreet Verify company legitimacy 2014 EPCOR.. All All rights reserved. 21
22 LexisNexis Verify company legitimacy 2014 EPCOR.. All All rights reserved. 22
23 Enhanced Due Diligence Third-Party Senders 2014EPCOR EPCOR.. All All rights rights reserved.
24 HOAs Homeowners Associations Property Rental Companies Difficult to identify parties involved & associated risks 2014 EPCOR. All rights reserved. 24
25 Third-Party Senders ODFI should know details Require TPSs to provide info Verify it s a legitimate business Request to see agreements 2014 EPCOR. All rights reserved. 25
26 Agreements Consider applicable regulations & laws 2014 EPCOR. All rights reserved. 26
27 5 ONBOARDING STEPS THAT LEAD TO BETTER RISK MANAGEMENT Underwrite Model Monitor Analyze Verify 27
28 ONBOARDING ACTIVITIES (1) KYC and KYCC (2) Modeling ACH Risk Monitoring Business Activities (3) and Transactions
29 ONBOARDING ACTIVITIES (1) KYC and KYCC Gather Data Score Risk Compare Business Type (2) Modeling ACH Risk Type Value Frequency Compare (3) Monitoring Business Activities and Transactions Business Activities Outside the Firewall Inside the Firewall Respond to Changes Limit Setting
30 ONBOARDING ACTIVITIES (1) KYC and KYCC Gather Data Score Risk Compare Business Type Know Your Customer KYC Require background check get a Credit Report Validate legitimacy of the business If necessary, supplement with background check on the principal business owners Consistency of data acquired 3 rd party senders KYC and KYCC Due diligence on the Third Party Senders Due diligence on the customers of the Third Party Senders Validating limits plus identifying and evaluating risk
31 ONBOARDING ACTIVITIES (1) Validate the firm find external data KYC and KYCC Gather Data Score Risk Compare Business Type Examine the data intrinsic risk, extrinsic risk Compare the data and the customer to your existing customers Establish a base line of data and monitor changes Establish a reaction plan if new results are negative Build an automated master calendar for reviews, notices, and renewal dates for each firm
32 ONBOARDING ACTIVITIES (1) KYC and KYCC Gather Data Score Risk Compare Business Type Evaluation Totals Total Argos Risk Accounts 1057 Account highlights: Foreclosed properties new owners 3 Inactive corp 4 Bankrupt Company 1 Money Service Businesses 1 Need additional info 70 Residential address 9 Unable to find 78 UPS PO Box 3 Total 166
33 ONBOARDING ACTIVITIES (1) KYC and KYCC Gather Data Score Risk Compare Business Type
34 ONBOARDING ACTIVITIES (1) KYC and KYCC Gather Data Score Risk Compare Business Type
35 ONBOARDING ACTIVITIES (1) KYC and KYCC ODFI THIRD PARTY SENDER PORTFOLIO Gather Data TPS #1 TPS #2 TPS #3 TPS #4 Score Risk Compare Customer 1 Customer 1 Customer 1 Customer 2 Customer 2 Customer 2 MSB MSB Customer 3 Customer 3 Customer 3 Customer 1 MSB Customer 2 Customer 3 Customer 4 Customer 4 Customer 4 Business Type Customer 5 Customer 5
36 ONBOARDING ACTIVITIES (1) KYC and KYCC Gather Data Score Risk Compare Business Type
37 ONBOARDING ACTIVITIES (1) Do you have a list of businesses that KYC and KYCC Gather Data Score Risk Compare Business Type you list as high risk or that you do not want to work with? TOD Terminated originator database Restricted types or industries? Travel Agencies Grocery Stores Fritz s Pub? 24 MSB s within 5 minutes of here 321 MSB s in Wisconsin
38 Terminated Originator Database EPCOR.. All All rights reserved. 38
39 ONBOARDING ACTIVITIES (1) KYC and KYCC Gather Data Score Risk Compare Business Type Restricted Types: Adult Sites (including Adult Novelties) Internet Casinos or Gambling of Any Kind, Including Odds Making Escort Services Out bound Telemarketing Fortune Tellers Collection Agencies / Debt Refinancing / Credit Restoration Pyramid Sales "Get Rich" or "Life Coach" Programs, Books, DVD's Sending of Money/Cash Advances Sale of Stocks, Securities, Options and Other Investments Merchant Account Factoring accepting payment for products you do not own Alcohol, Firearms, Tobacco Products & Drugs and Drug Paraphernalia Goods/Services prohibited by law or card associations
40 ONBOARDING ACTIVITIES (1) KYC and KYCC Gather Data Score Risk Compare Business Type (2) Modeling ACH Risk Type Value Frequency Compare (3) Monitoring Business Activities and Transactions Business Activities Outside the Firewall Inside the Firewall Respond to Changes Limit Setting
41 ONBOARDING ACTIVITIES (2) Modeling ACH Risk Type Value Frequency Compare Limit Setting
42 ONBOARDING ACTIVITIES (2) Modeling ACH Risk Type Value Frequency Compare Limit Setting
43 ONBOARDING ACTIVITIES (2) Modeling ACH Risk Type Value Frequency Compare Limit Setting
44 ONBOARDING ACTIVITIES (1) (2) Onboarding: KYC Modeling and KYCC ACH Risk Gather TypeData Score Value Risk Frequency Compare Business Compare Type (3) Monitoring Business Activities and Transactions Business Activities Outside the Firewall Inside the Firewall Respond to Changes Limit Setting
45 ONBOARDING ACTIVITIES (1) KYC and KYCC Gather Data Score Risk Compare Business Type (2) Modeling ACH Risk Type Value Frequency Compare (3) Monitoring Business Activities and Transactions Business Activities Outside the Firewall Inside the Firewall Respond to Changes Limit Setting
46 ONBOARDING ACTIVITIES (3) Monitoring Business Activities and Transactions Business Activities Argos Risk is OUTSIDE Systems Vendors that are INSIDE PPD Outside the Firewall Inside the Firewall Respond to Changes FIREWALL CCD RDC
47 ONBOARDING ACTIVITIES (3) Monitoring Business Activities and Transactions Business Activities Outside the Firewall Inside the Firewall Credit Score Years in Business Employees Payment Records Past Due Records Vendor Payment Volatility Amount of Legal Process Days Beyond Terms Percentage of Slow Pays Trade References Business Health Timely Payments High Credit Offered Multiple Trade References Lawsuits, Liens, Litigation Poor Industry trends Challenging Geography Declining Business Scores Payment Consistency Timely Payments Increased Credit Offered Trade References Low Past Dues Legal Process Filings Days Beyond Terms More Slow Payments Fewer Trade References Terms Consistency Payment Trends Increased Credit offered More References Fewer Past Dues Slow Payments Increased slow or negative payment activity Fewer Trade References ACH Risk Origination volume Frequency SEC type SEC Return Rates Industry Risk Class Temporal Risk Multiple Settlements ACH Risk Index Average Volume Peak Risk Respond to Changes
48 (3) Monitoring Business Activities and Transactions Business Activities ONBOARDING ACTIVITIES Business Name ACH Customer Profile Data Input 2 ACH Transaction Data Input 3 Outside the Firewall Input 1 Inside the Firewall Respond to Changes
49 ONBOARDING ACTIVITIES (3) Monitoring Business Activities and Transactions Business Activities Outside the Firewall Inside the Firewall Respond to Changes Actionable alerts: delivery at 6:00 AM CT Internal alerts Material change in scoring metrics External alerts: Slow paying vendors Lawsuits and liens Delayed or inaccurate financial reporting Changes in key personnel Mergers and acquisition information MSB authorizations Material negative event (ie: data breach incident)
50 ONBOARDING ACTIVITIES (3) Monitoring Business Activities and Transactions Business Activities Outside the Firewall Inside the Firewall Respond to Changes
51 ONBOARDING ACTIVITIES (3) Monitoring Business Activities and Transactions Business Activities Outside the Firewall Respond to changes! Lawsuit response? Executive change response? Risk profile changes? Bankruptcy? What have you planned as a response? Inside the Firewall Respond to Changes
52 CONTACT THE PRESENTERS Brent Siegel Argos Risk Wendy Wishon, AAP, NCP EPCOR
What Do You Need to Know to Know Your Customer? SFE Conference MaY 3, 2017 Biloxi MS
What Do You Need to Know to Know Your Customer? SFE Conference MaY 3, 2017 Biloxi MS Discussion Today What Does KYC / KYCC Really Mean? Types of Customers Risk Profiles Using the Data Ensuring Compliance
More informationManaging Third Party Risk in the ACH Network
Managing Third Party Risk in the ACH Network Tony DaSilva, AAP, CISA Senior Examiner Federal Reserve Bank of Atlanta Paul A. Carrubba Partner Adams and Reese LLP Disclaimer THE VIEWS AND OPINIONS EXPRESSED
More informationNACHA Third-Party Sender Certification Program Criteria
INTRODUCTION These Third-Party Sender Certification Program Criteria set forth the subject matter areas that will be reviewed by NACHA in order to determine whether an applicant ( Applicant ) satisfies
More informationAuthorizations & Agreements. Presented by Laura Nelson, AAP NCP Education Specialist/Auditor
Authorizations & Agreements Presented by Laura Nelson, AAP NCP Education Specialist/Auditor Audio Handouts Questions Presented by: PAR/WACHA - The Premier Payments Resource Laura Nelson, AAP, NCP Education
More informationACH Risk: Is It a Myth or Reality. Mary Gilmeister, AAP, NCP President WACHA Fred Laing, II, AAP, CCM, NCP President UMACHA
ACH Risk: Is It a Myth or Reality Mary Gilmeister, AAP, NCP President WACHA Fred Laing, II, AAP, CCM, NCP President UMACHA Disclaimer WACHA and UMACHA, through their Direct Membership in NACHA, are specially
More informationSame Day ACH, Third-Party Sender Registration and Other Payments Initiatives, Oh My! Discussion. Faster Payments. Central OK AFP March 23, 2017
Same Day ACH, Third-Party Sender Registration and Other Payments Initiatives, Oh My! Central OK AFP March 23, 2017 Wendy Wishon, AAP, NCP EPCOR 2017, EPCOR. All Rights Reserved. 1 Discussion Faster Payments
More informationACH Audit and Risk Assessment: Choose Your Own Adventure
THE PAYMENTS INSTITUTE July 17-20, 12-15, 2016 2015 Emory Conference Center Hotel, Emory University, Atlanta, Georgia ACH Audit and Risk Assessment: Choose Your Own Adventure Mary Gilmeister AAP, NCP President
More informationPayment System Rules and Regulations. What will you learn? After this course, you will be able to:
Payment System Rules and Regulations Regional Payments Associations, through their Direct Membership in NACHA, are specially recognized and licensed providers of ACH education, publications and support.
More informationNavigating the ACH Rules
Navigating the 2018 ACH Rules This material is not intended to provide any warranties or legal advice, and is intended for education purposes only. NACHA owns the copyright for the NACHA Operating Rules
More informationHow to Ace Your BSA Exam & Risk Assessment
How to Ace Your BSA Exam & Risk Assessment LeVar Anderson, CAMS, AAP Auditor, Carolinas Credit Union League Agenda NCUA Examiners review compliance with BSA as part of every exam cycle using examination
More information2017 WEBINAR SCHEDULE Affordable training, when and where you choose
2017 WEBINAR SCHEDULE Affordable training, when and where you choose With engaging, hot-topic webinars from your Association, you get all of the benefits of a classroom, without the time and hassle of
More informationSame Day ACH: What Does It Mean to Your Financial Institution?
Same Day ACH: What Does It Mean to Your Financial Institution? Presented by WACHA Pre- Conference PAR/WACHA-The Premier Payments Resource Panelists: Laura Parsons FIS Wendy Stanford Bankers Bank Stacy
More informationGet on First Base with Same-Day ACH Risks
Get on First Base with Same-Day ACH Risks EASTPAY 2016 Information Interchange Mary Gilmeister, AAP, NCP President WACHA Fred Laing, II, AAP, CCM, NCP President UMACHA 1 Disclaimer NACHA owns the copyright
More informationKYC Automation: Scale, Speed, Standardize Merchant Underwriting
Know Your Customer (KYC) KYC Automation: Scale, Speed, Standardize Merchant Underwriting Visit www.macmember.org to join in MAC Benefits include: Protect and invest in your organization by receiving fraud
More informationA CONSUMER S GUIDE TO INSURANCE COMPANIES' USE OF CREDIT INFORMATION
A CONSUMER S GUIDE TO INSURANCE COMPANIES' USE OF CREDIT INFORMATION INSURANCE CREDIT SCORING IN NORTH CAROLINA Insurance companies licensed to sell private passenger automobile and residential property
More informationACH Industry Update, Audit Weaknesses and Emerging Payment Trends
ACH Industry Update, Audit Weaknesses and Emerging Payment Trends Presented by Adrian Brown, AAP Director of Education The Payments Authority is the association for payments people. ACH CARD CHECK WIRE
More informationConducting KYC of Third Parties: Best Practices for Conducting Due Diligence
Conducting KYC of Third Parties: Best Practices for Conducting Due Diligence Risk-Based Due Diligence of Third Parties Shaswat Das Hunton Andrews Kurth LLP April 2018 Why Conduct Third Party Due Diligence?
More informationACH Management Policy
ACH Management Policy Original Issue Date: December 16, 2003 Last Revision Date: February 27, 2018 Last Review Date: February 27, 2018 Next Review Date: February 2019 Page 1 of 5 ACH Management Policy
More informationBSA/AML Hot Topics and UIGEA Daniel Hastings Financial Institution Examiner - FDIC
BSA/AML Hot Topics and UIGEA Daniel Hastings Financial Institution Examiner - FDIC Common BSA Deficiencies Revised FFIEC BSA/AML Examination Manual Proposed CDD Requirements for Financial Institutions
More informationDefinitions AML/BSA Risks Assess Your Risks Identify the Risks Mitigate the Risks Scenario Questions?
Definitions AML/BSA Risks Assess Your Risks Identify the Risks Mitigate the Risks Scenario Questions? 2 BSA Bank Secrecy Act Currency and Foreign Transactions Reporting Act, is legislation passed by the
More informationNEACH Payments Management Conference ACH Credit Risk: Credits, Debits, Same Day
ACH Credit Risk: The Credits, The Debits and The Same Day ACH Effect Jennifer Wasmund, AAP, NCP, Vice President of Education and Compliance, UMACHA www.neach.org 2016 NEACH. All rights reserved. Jen Wasmund,
More informationUMACHA 2014; All rights reserved 2
Mitch Kenady, AAP Compliance Services Specialist Dahlia Penland, AAP Compliance Services Specialist Regional Payments Associations, through their Direct Membership in NACHA, are specially recognized and
More informationORIGINATING ACH ENTRIES REFERENCE
ORIGINATING ACH ENTRIES REFERENCE The following information has been provided so that customers can be familiar with their requirements under the NACHA Operating Rules (The Rules). This quick reference
More informationBSA/AML & OFAC Volunteer Compliance Training. Agenda
Ideas + Solutions = Success BSA/AML & OFAC Volunteer Compliance Training Ideas + Solutions = Success Presented by Dorie Fitchett HCUL Regulatory Officer May 17, 2018 Agenda 1. Bank Secrecy Act 2. Office
More informationSame Day ACH: Preparing for Debits. Presented by Laura Nelson, AAP NCP Education Specialist/Auditor
Same Day ACH: Preparing for Debits Presented by Laura Nelson, AAP NCP Education Specialist/Auditor Audio Handouts Questions Presented by: PAR/WACHA-The Premier Payments Resource Laura Nelson, AAP, NCP
More informationAutomated Clearing House
Automated Clearing House THE SERVICE Customer wishes to initiate credit and/or debit Entries as an Originator through Bank to Accounts maintained at Bank and in other depository financial institutions
More informationRepresentment Terms & Conditions
5500 Brooktree Road, Suite 104 Wexford, PA 15090 888-436-5101 www.profituity.com Representment Terms & Conditions Please read the following Terms and Conditions carefully. Company should note that the
More informationNACHA Operating Rules: What Do They Mean to You?
NACHA Operating Rules: What Do They Mean to You? 2015 NACHA The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA.
More informationACH FUNDAMENTALS: UNDER THE MICROSCOPE. Heather Spencer, AAP Implementation Coordinator, MY CU Services, LLC. Disclaimer
ACH FUNDAMENTALS: UNDER THE MICROSCOPE Heather Spencer, AAP Implementation Coordinator, MY CU Services, LLC www.mycuservices.com Disclaimer This material is not intended to provide any warranties or legal
More informationCHARTER PEOPLE S UNITED FINANCIAL, INC. ENTERPRISE RISK COMMITTEE
CHARTER PEOPLE S UNITED FINANCIAL, INC. ENTERPRISE RISK COMMITTEE Purpose and Authority: The Enterprise Risk Committee (the Committee ) has been established by the Board of Directors of People s United
More informationREGULATION GG YOUR NEW OBLIGATIONS TO STOP UNLAWFUL INTERNET GAMBLING
REGULATION GG YOUR NEW OBLIGATIONS TO STOP UNLAWFUL INTERNET GAMBLING BY AMY AVITABLE ASSOCIATE DIRECTOR METAVANTE REGULATORY SERVICES SPRING 2009 Agenda Overview of requirements What is unlawful internet
More informationTerms and Conditions for Certificate of Deposit Accounts
for Certificate of Deposit Accounts Effective May 1, 2018 Including: Arbitration Agreement Early Withdrawal Penalties Table of Contents TABLE OF CONTENTS IMPORTANT NOTICE CONCERNING FDIC INSURANCE... 1
More informationSame Day ACH Transaction Risk
Same Day ACH Transaction Risk The Clearing House Puerto Rico Payment Symposium August 21, 2015 Same Day Risk Agenda: Same Day ACH Background Settlement Operations Returns Risk Associated with Same Day
More informationBank Secrecy Act Hot Topics August 29, 2017
Bank Secrecy Act Hot Topics August 29, 2017 David A. Larocque, CAMS Regulatory Compliance Supervisor MEMBER OF ALLINIAL GLOBAL, AN ASSOCIATION OF LEGALLY INDEPENDENT FIRMS 2017 Wolf & Company, P.C. Before
More informationBank Secrecy Act. The board establishes adequate policies and procedures in accordance with anti-money laundering laws and regulations.
Bank Secrecy Act Standards Examiners should evaluate the above-captioned function against the following control and performance standards. The Standards represent control and performance objectives that
More informationThis is designed to provide those who are not familiar with the ACH Network with a basic understanding of the fundamentals of the ACH Network.
This is designed to provide those who are not familiar with the ACH Network with a basic understanding of the fundamentals of the ACH Network. The ACH Network is a batch processing, store and forward system.
More informationNew Servicing Rules under RESPA Early Intervention, Continuous Contact and Loss Mitigation
New Servicing Rules under RESPA Early Intervention, Continuous Contact and Loss Mitigation FIS Regulatory Advisory Services Regulatory.Services@fisglobal.com New Servicing Rules Under RESPA Early Intervention,
More informationBSA/AML Literacy Test 1
BSA/AML Literacy Test 1 Please Note: The Basic Training consists of three videos approximately 15 minutes each, and should be viewed first. A lot of the following material is also to be found in the Basic
More informationSmall Business Loan Guaranty Program
Revised April 2013 Small Business Loan Guaranty Program Overview Created as part of the Small Business Jobs Act of 2010, the State Small Business Credit Initiative (SSBCI) was designed to help increase
More informationSurvey of Consumer Payment Choice: Preliminary Results 2008
Survey of Consumer Payment Choice: Preliminary Results 2008 Marianne Crowe Federal Reserve Bank of Boston FedExchange 2009 May 6, 2009 Presentation Overview Survey of Consumer Payment Choice (SCPC) Program
More informationKey Components of an RDFI. Mini Deck
Key Components of an RDFI Mini Deck Disclosure 2017 PaymentsFirst. All rights reserved. This material is not intended to provide any warranties or legal advice, and is intended for educational purposes
More information5/2/2017. Mini Deck. Disclosure
Key Components of an RDFI Mini Deck Disclosure 2017 PaymentsFirst. All rights reserved. This material is not intended to provide any warranties or legal advice, and is intended for educational purposes
More informationP2P, A2A Payments: Perils to Protection. WACHA Conference 2016 Kimberly W. Rector, AAP
P2P, A2A Payments: Perils to Protection WACHA Conference 2016 Kimberly W. Rector, AAP You Know the Drill The views and opinions expressed in this presentation are those of the presenter (and it is likely
More informationSTATEMENT OF ANTI-MONEY LAUNDERING (AML) AND COMBATING THE FINANCING OF TERRORISM (CFT) POLICIES AND PRINCIPLES
STATEMENT OF ANTI-MONEY LAUNDERING (AML) AND COMBATING THE FINANCING OF TERRORISM (CFT) POLICIES AND PRINCIPLES Scope AstroBank Limited (the Bank ) has established and implemented appropriate policies
More informationCopyright 2017 Lakeland Bank. All rights reserved. This material is proprietary to and published by Lakeland Bank for the sole benefit of its
ACH Originator Guide Copyright 2017 Lakeland Bank. All rights reserved. This material is proprietary to and published by Lakeland Bank for the sole benefit of its clients. Reproduction, distribution, disclosure
More informationBusiness Classification Best Practices NAICS IN A KYC WORLD
Business Classification Best Practices NAICS IN A KYC WORLD Table of Contents: Executive Summary Problem Definition Detailed Solution Business Benefits Conclusion Executive Summary The FFIEC BSA/AML Examination
More informationIdentify and Monitor High- Risk and Money Service Businesses Accounts. Presented by Lynn English Lafayette Federal Credit Union
Identify and Monitor High- Risk and Money Service Businesses Accounts Presented by Lynn English Lafayette Federal Credit Union Key Takeaways After this webinar, participants should have an understanding
More informationTREASURY MANAGEMENT MASTER AGREEMENT TERMS AND CONDITIONS
TREASURY MANAGEMENT MASTER AGREEMENT TERMS AND CONDITIONS PLEASE NOTE THAT THESE TERMS AND CONDITIONS ARE A PART OF THE TREASURY MANAGEMENT MASTER AGREEMENT WHICH YOU HAVE READ AND SIGNED. ALL TERMS AND
More informationBSA/AML Excellence and the Role of Governance NEW JERSEY BANKERS ASSOCIATION ANNUAL CONFERENCE MAY 2017
BSA/AML Excellence and the Role of Governance NEW JERSEY BANKERS ASSOCIATION ANNUAL CONFERENCE MAY 2017 Your Presenters Asaad Faquir, MBA, MBS Director, RSK Compliance Solutions, LLC Salvatore Zerilli,
More information(b) "Consumer report" has the meaning given in 15 USC 1681a (d). (c) "Consumer reporting agency" has the meaning given in s. 15 USC 1681a (f).
Wisconsin Statutes Agriculture; Foods and Drugs Markets Chapter 100 Marketing; Trade Practices 100.54. Access to credit reports. (1) Definitions. In this section: (a) "Business day" means a business day,
More informationMain Street Bank EXTERNAL FUNDS TRANSFER AGREEMENT
Main Street Bank EXTERNAL FUNDS TRANSFER AGREEMENT ACCEPTANCE OF TERMS This Agreement sets out the terms and conditions (Terms) upon which Main Street Bank (Bank) will provide the ability to perform external
More informationCredit Card Agreement for Consumer Secured Cards in Capital One Bank (USA), N.A.
Credit Card Agreement for Consumer Secured Cards in Capital One Bank (USA), N.A. There are two parts to this Credit Card Agreement: Capital One Pricing Information and the Capital One Customer Agreement.
More informationBank Secrecy Act- USA Patriot Act Compliance
Bank Secrecy Act- USA Patriot Act Compliance Federal Laws Regulating Money Service Businesses Bank Secrecy Act (1970) Establishes recording of high dollar transactions & the reporting of suspicious activity
More informationAccount Opening Disclosures
Account Opening Disclosures Interest Rates and Interest Charges 0.00% Introductory APR for seven cycles Annual Percentage Rate (APR) for Purchases APR for Balance Transfers APR for Cash or ATM Advances
More information15.90% Classic MasterCard. Interest Rates and Interest Charge Annual Percentage Rate (APR) for Purchases
Classic MasterCard Interest Rates and Interest Charge Annual Percentage Rate (APR) for Purchases 15.90% APR for Balances Transfers APR for Cash Advances Grace Period for Repayment of Balances for Purchases
More informationAs used in sections to , the following terms shall mean:
Missouri Statute 407.1380. Definitions. As used in sections 407.1380 to 407.1384, the following terms shall mean: (1) "Account review", activities related to account maintenance, monitoring, credit line
More informationBank Of America Corporation Aml Policy Manual
Bank Of America Corporation Aml Policy Manual American Gaming Association. Best Practices Bank Secrecy Act and associated anti-money laundering (AML) statutes and regulations. Risk- The goal of this document
More informationCredit365.com BUSINESS CREDIT
e Credit365.com BUSINESS CREDIT Now you can get prequalified for the working capital or business credit you need to startup and grow regardless of personal credit.** Register for our FREE webcast about
More informationLOAN OFFICER NAME: OFFICE PHONE: CELL PHONE: FAX: ADDRESS: AFFILIATE NAME: COMPANY NAME: BROKER NAME: BROKER PHONE: BROKER
Loan Application Complete the entire application. Failure to complete can cause delays in funding 701 E. Front Ave., Floor, Coeur d'alene, ID 83814 LOAN OFFICER NAME: OFFICE PHONE: CELL PHONE: FAX: EMAIL
More informationPuerto Rican 13 th Symposium of Anti Money Laundering. February 24 25, 2016
Puerto Rican 13 th Symposium of Anti Money Laundering February 24 25, 2016 Cuban Sanctions/Background The Cuba sanctions, which are based on the Trading with the Enemy Act (TWEA), are very broad Prohibit
More informationUtah Bankers Association CRA Conference Investments - Underwriting and Risk Strategy
Utah Bankers Association CRA Conference Investments - Underwriting and Risk Strategy Will Whetstone American Express Center for Community Development American Express Center for Community Development This
More informationLOAN OFFICER NAME: OFFICE PHONE: CELL PHONE: FAX: ADDRESS: AFFILIATE NAME: COMPANY NAME: BROKER NAME: BROKER PHONE: BROKER
Loan Application Complete the entire application. Failure to complete can cause delays in funding 701 E. Front Ave., Floor, Coeur d'alene, ID 83814 LOAN OFFICER NAME: OFFICE PHONE: CELL PHONE: FAX: EMAIL
More informationStrategies for Switching Small Businesses from Checks to ACH
Strategies for Switching Small Businesses from Checks to ACH Peter McVey, AAP, NCP Director, Treasury Services Lead Bank Mary Hughes Senior Payments Consultant Federal Reserve Bank of Minneapolis PAYMENTS
More informationPROVIDER REGISTRATION APPLICATION FOR THE STATE OF OHIO Ohio Power Company d/b/a AEP Ohio
FOR THE STATE OF OHIO Ohio Power Company d/b/a AEP Ohio Application for Competitive Retail Electric Service Provider (CRES) registration in AEP Ohio (the "Company") includes both rate jurisdictions: Columbus
More informationUCC 4A and the ACH Network. Presented by Wanda Downs, AAP Director of Payments Education
UCC 4A and the ACH Network Presented by Wanda Downs, AAP Director of Payments Education 2018 Audio Handouts Questions UCC 4A AND THE ACH NETWORK Wanda Downs, AAP Director of Payments Education Disclaimer
More informationRecent Changes to the FFIEC Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual
Recent Changes to the FFIEC Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual Recent Changes to the FFIEC Bank Secrecy Act / Anti-Money Laundering (BSA / AML) Examination Manual For quite
More informationAutomate and Streamline Your Consumer and Small Business Lending. Jamie Williams, Business Development Laurie Otero, NAL Consumer Product Manager
Automate and Streamline Your Consumer and Small Business Lending Jamie Williams, Business Development Laurie Otero, NAL Consumer Product Manager April 12, 2017 Holistic lending strategy Loan Origination
More informationTable of Contents. Money Smart for Small Business Page 2 of 19
Table of Contents Welcome... 4 What Do You Know? Credit Reporting for a Small Business... 5 Pre-Test... 6 Credit Reporting... 7 Credit Report Impact... 7 Business Credit Reports... 7 Discussion Point #1:
More informationApplied Risk Management
THE PAYMENTS INSTITUTE July 20-23, 2014 Emory Conference Center Hotel, Emory University, Atlanta, Georgia Applied Risk Management Norman Robinson, AAP. CTP President & CEO EastPay, Providing Payments Expertise
More informationOFAC Compliance Officer Responsibilities. OFAC Regulations. Transactions Subject to OFAC. Reviewed by and Date:
OFAC Compliance Officer Responsibilities NorthPark has designated as the BSA/CIP/OFAC Compliance Officer. The BSA Officer will maintain and update the policies. At least annually the policy will be reviewed
More informationAlliant Cashback Visa Signature Card Agreement
January 2018 P390-R01/18 Alliant Cashback Visa Signature Card Agreement In this Agreement the words you and your mean each and all of those who agree to be bound by this Agreement; Credit Card or Card
More informationAccount Disclosures. RDFI should review and update account disclosures to address:
IAT for the RDFI RDFI Obligations Account Disclosures OFAC Screening (Accounts) Acceptance and Screening of IAT Transactions Policies and Procedures (including OFAC) IAT Credit Processing Sample Procedures
More informationTD Cash SM Secured Important Credit Card Terms and Conditions
TD Cash SM Secured Important Credit Card Terms and Conditions Rates, fees, and other important costs of the TD Cash Secured Credit Card are disclosed below. Additional fees and account terms are described
More informationRisk Based Approach to Customer Due Diligence
Risk Based Approach to Customer Due Diligence Rick Small Citigroup, Inc. John Byrne American Bankers Association August 22, 2005 Risk Model Objectives At Account Opening: Determine appropriate level and
More informationOCC Policy Statement on Tax Refund-Related Products
OCC Policy Statement on Tax Refund-Related Products The Office of the Comptroller of the Currency (OCC) is issuing the following policy statement setting forth the measures national banks are expected
More informationCurrent Credit Card Agreements for New Business Accounts
Current Credit Card Agreements for New Business Accounts For new business accounts opened beginning 04/23/2018, the following Account Opening Disclosures and Credit Card Agreement apply by the credit card
More informationIndiana OR/WA/HI Tri-State Conference Mortgage Servicing. Sonia Lee Director, Affiliate Financial Service HFHI
Indiana 2015 OR/WA/HI Tri-State Conference Mortgage Servicing Sonia Lee Director, Affiliate Financial Service HFHI Mortgage Servicing Mortgage Servicing New Policy 24 Mortgage Loan Servicing What is mortgage
More informationKentucky Revised Statutes Title XXIX Commerce and Trade Chapter 367 Consumer Protection
Kentucky Revised Statutes Title XXIX Commerce and Trade Chapter 367 Consumer Protection 367.363. Definitions for KRS 367.363 to 367.365. As used in KRS 367.363 to 367.365, unless the context requires otherwise:
More informationHOW TO READ THE BUSINESS INFORMATION REPORT
HOW TO READ THE BUSINESS INFORMATION REPORT The Business Information Report (BIR) is the most widely used Dun & Bradstreet report. The BIR attempts to provide information and analysis to help you evaluate
More informationVisa Platinum Card Visa Platinum Secured Card Visa Signature Rewards Card. Consumer Credit Card Agreement
Consumer Credit Card Agreement 1212 Huxley St Madison, WI 53704-4224 1-888-432-8496 In this Agreement, Agreement means this Consumer Credit Card Agreement. Disclosure means the Credit Card Account Opening
More informationCredit Card Agreement and Disclosure Statement
Credit Card Agreement and Disclosure Statement G-16871 Your Lifetime Financial Partner In this Agreement the words you and your mean each and all of those signing, using or having a credit Card account
More informationMerchant Referral Program Introduction
Merchant Referral Program Introduction 2018 Introduction to OnDeck The leading online platform for small business lending $8 Billion+ total originations 70,000+ small businesses served Global in United
More informationMerchant Application
MERCHANT INFORMATION Salesman I.D. or Name: Legal Name: DBA Name: Street Address: City: State: Zip: Country: Contact: Phone: Email: Fax: Date Business Started: Years at this location: Num. of Locations:
More informationCREDIT RISK MANAGEMENT GUIDANCE FOR HOME EQUITY LENDING
Office of the Comptroller of the Currency Board of Governors of the Federal Reserve System Federal Deposit Insurance Corporation Office of Thrift Supervision National Credit Union Administration CREDIT
More informationCASH MANAGEMENT SCHEDULE. AUTOMATED CLEARING HOUSE SERVICES for Originators & Third-Party Senders
CASH MANAGEMENT SCHEDULE AUTOMATED CLEARING HOUSE SERVICES for Originators & Third-Party Senders This Schedule is entered into by and between Santander Bank, N.A. ( Bank ) and Customer identified in the
More informationCORPORATE USER ACH QUICK REFERENCE CARD
What is the ACH Network? The Automated Clearing House (ACH) Network is the a network created for the electronic movement of money and other related data. This is a safe, secure, and reliable network for
More informationPREPAID CARD GLOSSARY
PREPAID CARD GLOSSARY ACH Remitter: The bank that receives the electronic funds transfer via Automated Clearing House (ACH) to load funds to a prepaid card. A known remitter is one that is logged in the
More informationADDENDUM TO ONLINE BANK AGREEMENT FOR CASH MANAGEMENT SERVICES- AUTOMATED CLEARING HOUSE ODFI ORIGINATOR AGREEMENT (S-1)
ADDENDUM TO ONLINE BANK AGREEMENT FOR CASH MANAGEMENT SERVICES- AUTOMATED CLEARING HOUSE ODFI ORIGINATOR AGREEMENT (S-1) THIS AGREEMENT is made this day of,, by and between (the "Customer") and Israel
More information2018 ICBA Regulator Panel Agricultural Lending
2018 ICBA Regulator Panel Agricultural Lending March 15, 2018 Keith Osborne ADC Wichita Field Office 1 Agenda Agricultural Lending Risk Management Practices Risk Rating Agricultural Loans References Questions
More information13.74% to 19.74% based on your creditworthiness. This APR will vary with the market based on the Prime Rate.
Interest Rates and Interest Charges Standard Mastercard /Visa Variable Rate (including Secured) Annual Percentage Rate (APR) for Purchases 13.74% to 19.74% based on your creditworthiness. This APR will
More informationCITIZENS, INC. BANK SECRECY ACT/ ANTI-MONEY LAUNDERING POLICY AND PROGRAM
I. Introduction CITIZENS, INC. BANK SECRECY ACT/ ANTI-MONEY LAUNDERING POLICY AND PROGRAM The Bank Secrecy Act/Anti-Money Laundering Responsibilities of Insurance Companies U.S. insurance companies have
More informationComprehensive Payables
Comprehensive Payables Ideas on how to streamline the electronic payment process MCCBOA Presentation Thursday, March 5, 2015 Presented by: Jose ph Kiss Matthew Kovack, AAP Christopher Brin SVP, Market
More informationSetting Policies at the Board Level Agenda
Setting Policies at the Board Level Agenda What is a Policy? Guidance Policies vs. Procedures Writing Policies Resources Required Policies 1 What is a Policy? A definite course or method of action selected
More informationCU PolicyPro Alphabetical Policy Listing
A 3160 2235 7332 2222 2215 3000 6120 8110 2210 3105 2216 2214 2212 2210 2213 11003 2610 2612 2611 1000 11005 9430 11016 5100 5110 7615 9500 Abandoned Property (Unclaimed Property) Abusive Member (Member
More informationFFIEC REMOTE DEPOSIT GUIDANCE. Presented by: PAUL A. CARRUBBA Adams and Reese LLP Phone: (601)
FFIEC REMOTE DEPOSIT GUIDANCE Presented by: PAUL A. CARRUBBA Adams and Reese LLP Phone: (601) 292-0788 E-Mail: paul.carrubba@arlaw.com Paul Carrubba 2 Paul is a partner in the law firm of Adams and Reese
More informationVisa Classic Secured Credit Card Account Disclosures
Visa Classic Secured Credit Card Account Disclosures 17151 Chesterfield Airport Rd. Chesterfield, MO 63005 PH: 636-728-3330 TF: 800-905-7585 firstcommunity.com INTEREST RATES AND INTEREST CHARGES Annual
More informationWire Transfer & ACH Origination. What will you learn? Wire Transfer Origination. After this course, you will be able to:
Wire Transfer & ACH Origination Regional Payments Associations, through their Direct Membership in NACHA, are specially recognized and licensed providers of ACH education, publications and support. Regional
More informationBusiness Deposit Account Application
Business Eligibility Business Location in Metro Atlanta Business Information Legal Name of Business: DBA (if applicable): County Principal Business Address: Business Owner is Current Primary Member Federal
More informationExternal Account Transfer Agreement July 16, 2014
External Account Transfer Agreement July 16, 2014 Welcome to Altra Federal Credit Union s External Accounts Transfer Service. With this Service, you may transfer funds from your Credit Union account(s)
More informationCommercial Credit Risk Analysis and Approval: Behind the Scenes. January 21, 2016
Commercial Credit Risk Analysis and Approval: Behind the Scenes January 21, 2016 Comerica Bank Presenters Joyce Conley, CTP, Vice President, Treasury Management Sales Joyce joined Comerica Bank in 2012
More information