Preparing For The Day After Tomorrow

December 19, 2017 at 9:01 am Leave a comment

Image result for the day after tomorrowI have a lot of stuff I want to get done before going on my Christmas hiatus, so this is going to be short and sweet. There are two recently released guidance your compliance person should know about.

First, there is this joint interagency examiner guidance informing field staff how to assess a financial institution’s response to a major disaster. Let’s be honest people, the climate is acting stranger than usual and there is the unfortunate reality that your credit union and the community in which it is located could be impacted by a major disaster. How your credit union responds to these disasters is the thrust of this guidance which will be used by NCUA examiners. It stresses that examiners should assess “management’s effectiveness in responding to the changes in an institution’s bushiness markets as a result of a natural disaster and whether the institution has addressed these issues by adjusting its long-term business strategy.” In addition, examiners should expect that institutions affected by a major disaster to conduct an initial risk assessment and the ability to refine this assessment on an ongoing basis.

There is more here than meets the eye. Your institution should review this guidance and update its existing policies and procedures to reflect its concerns. You don’t want to be developing an ad hoc disaster response plan after the disaster has occurred.

A second guidance that I wanted to give you a head’s up on has to deal with our erstwhile friend, the Bank Secrecy Act (BSA). FinCEN recently announced that it had updated its ever helpful list of frequently asked BSA questions. Among the changes are an updated response to Question 16 which deals with how to report a transaction involving a government official who engages in a financial transaction greater than $10,000 as part of his or her official duties. In other words, this response would have been of no use to Elliot Spitzer.

Finally, I am pleased to report that a little less than a week ago the Federal Reserve came out with another addition of the Consumer Compliance Outlook. I was afraid that the Federal Reserve wasn’t producing these anymore which is too bad because I consider them a great resource. Typically the Reserve provides an overview of new regulations which are not so general as to be of no use to the compliance professional but not so specific as to be of little interest to the non-compliance executive.

On that note, enjoy your day and remember to follow me on Twitter @HMeierEsq. By the way, I saw The Day After Tomorrow for the first time a few weeks ago. I usually find apocalyptic adventure movies idiotic and predictable but for some reason there was something about this idiotic and predictable movie that I enjoyed. 


Entry filed under: Compliance, Regulatory. Tags: , .

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Authored By:

Henry Meier, Esq., Senior Vice President, 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. In addition, although Henry strives to give his readers useful and accurate information on a broad range of subjects, many of which involve legal disputes, his views are not a substitute for legal advise from retained counsel.

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