Five Things To Ponder on a Thursday Morning

October 15, 2015 at 9:32 am Leave a comment

RBC II: This Time Its Serious

It’s a big day in CU land today. If all goes according to plan the NCUA board will vote to finalize a revised Risk Based Capital framework. With the announcement we will know the asset threshold at which credit unions will have to comply with the more sophisticated framework, the precise risk weightings that will be given to their assets, how much they will need to be considered “well capitalized” and the deadline by which they will have to fully comply with this new framework. If I were you I would tune in and watch the live webcast of the Board meeting today at 10:00 AM. It promises to be both informative and  entertaining although not quite as entertaining as yesterday’s game between the Toronto Blue Jays and the Texas Rangers but it will be pretty close.

New SAR Data Released

FinCen’s annual report on SAR filings came out yesterday and anyone involved with BSA enforcement should take some time to skim it. For one thing, it provides a good source of the emerging trends in criminality for which you should be on the lookout. For example, this year’s report indicates that depository institutions have seen a large increase in “funnel activity” which is closely related to drug financing. As described by FinCen in a 2011 Guidance   “Funnel account activity often involves a customer structuring currency deposits into an account in one geographic area, with the funds subsequently withdrawn in a different geographic region with little turn-around time.” (FIN-2011-A009, April 21, 2011)

FinCen is also rolling out a new interactive SAR activity report that will be updated on an ongoing basis and that allows you to search for specific SAR trends and geographic information. Here are some links to the latest report and interactive website.

  http://www.fincen.gov/Reports/SARStats

http://www.fincen.gov/news_room/rp/files/SAR02/SAR_Stats_2_FINAL.pdf

DFS Issues Symphony Software Warning

If you are a state charter here is one for your IT person to take a look at. NY’s Department of Financial Services issued a letter to  state regulated   Institutions yesterday related to the use of a third-party e-communications platform engineered by Symphony Communication Services LLC (“Symphony”). Symphony enables encrypted data to be sent between the sender and receiver. What has the DFS concerned is that the company’s promotional promise of   “guaranteed data-deletion” may result in violations of record retention requirements. Here is a link to the Letter: http://www.dfs.ny.gov/banking/agree_symphony_10132015.htm

While Congress Slept

As Paul Ryan continues his performance of Hamlet on the Potomac (“To be or not to be Speaker? That is the question”) reality is coming dangerously close to intruding on politics. In case Congress is interested, its own budget office predicted Wednesday that, absent a deal to raise the national debt, the “Treasury will begin running a very low cash balance in early November and the extraordinary measures will be exhausted and the cash balance entirely depleted sometime during the first half of November. At such time, the government would be unable to fully pay its obligations, a development that would lead to delays of payments for government activities, a default on the government’s debt obligations, or both.”

https://www.cbo.gov/publication/50891

   Angry up North

Speaking of yesterday’s Toronto game, former Yankee announcer Frank Messer used to say you see something new every time you watch a baseball game and truer words were never spoken.

In case you had something better to do with your time yesterday, like getting the kids home from school or talking with your spouse, what you need to know is that the Texas Rangers scored the go ahead run in the seventh inning of the series deciding game after Toronto catcher Russell Martin mistakenly hit Texas batter Shin-Soo Choo as he tried to throw the ball back to Texas pitcher Aaron Sanchez. I’ve never seen a catcher do this. After all getting the ball back to the pitcher is a pretty basic part of the game. Everyone,   including the ESPN radio announcers, thought the play was dead and paid no attention to the fact that Rougned Odor ran home from third base.

That was until Rangers manager Jeff Banister went out to argue with the umpires who, after several minutes, ruled that a run had scored. It was a play worthy of Little League and the fans responded by throwing as much beer on the field as Labatts sells in a day.

I never thought you could get 48,000 Canadians to lose their temper watching anything but a hockey game. Its a good thing Toronto ended up winning.

Could someone please explain to me how a run can score after the umpire ruled the play dead?

Entry filed under: Compliance, General, New York State. Tags: , , .

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Authored By:

Henry Meier, Esq., General Counsel, New York Credit Union Association.

The views Henry expresses are Henry’s alone and do not necessarily reflect the views of the Association.

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