Compliance Briefing for Monday, September 21, 2020

To access specific issuances, go to our Top Stories section, where you'll find links to all the relevant documents.
NO FALSE NEGATIVES
The Minimum BSA/AML Compliance Standard
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FEMA suspends communities in AK, AZ, IA and WA
On Friday, FEMA published a notice that it was suspending, as of September 18, communities in Alaska, Arizona, Iowa and Washington from the National Flood Insurance Program for noncompliance with the floodplain management requirements of the program.
  • Alaska: Fairbanks Northstar Borough and the City and Borough of Juneau
  • Arizona: Goodyear
  • Iowa: Harpers Ferry, Lansing, Postville, Waterville, and unincorporated areas of Allamakee County
  • Washington: Chehalis Reservation, Elma, Montesano, Oakville, and unincorporated areas of Grays Harbor County
Money Mules Moving Illicit Proceeds from COVID-19-Related Crimes
[Blog]
With millions of dollars stolen from consumers in the first half of 2020 through COVID-19-related fraud scams, criminals are exploiting money mules to launder the illicit proceeds. Learn more about sophisticated mule schemes during the pandemic, and why a consolidated fraud and AML platform is essential to fight back.
— Verafin

FTC requests comments on Prescreen Opt-Out Notice Rule
The Federal Trade Commission has published a notice of proposed rulemaking and request for public comment concerning its Prescreen Opt-Out Notice Rule. The Commission seeks public comment on the Rule and proposes to amend the Rule to conform to changes made to the Fair Credit Reporting Act by the Dodd-Frank Act, and to reinstate a model prescreen opt-out notice.

Comments are due by December 7, 2020.

Keeping Staff Engaged and Low Risk During COVID-19
Communication Strategies Keep Teams Diligent and Accountable
A great hire is a senior leader who creates a culture of communication and feedback that ensures their teams are mindful of regulations. The best leaders in these times use short, recurring meetings like virtual 1-on-1's, daily statuses and check-ins to keep staff aware and involved. Financial Professionals sources candidates with today's top communication methods in mind.
— Financial Professionals

Main Street Lending Program FAQs updated
The Federal Reserve Board has updated its FAQs to clarify the Board's and Department of Treasury's expectations regarding lender underwriting for the Main Street Lending Program. The revised FAQs emphasize that lender underwriting should look back to the borrower's pre-pandemic condition and forward to their post-pandemic prospects. The FAQs also clarify supervisory expectations for lenders originating Main Street loans.

Same Day ACH changes due in March
FRBServices has posted a notice that the countdown to the March 19, 2021, new processing window for Same Day ACH now stands at six months. The ACH Rules change, initially announced in September 2018, will establish a third and later same day ACH processing and settlement window with a settlement deadline of 4:45 p.m. ET and settlement at 6 p.m. ET. In support of the new processing window, the Federal Reserve Board in December 2019 approved modifications to FedACH Services, National Settlement Service, and Fedwire Funds Service to also be implemented in March 2021.

FDIC Oregon wildfire and wind relief
The Federal Emergency Management Agency declared a federal disaster for selected areas affected in Oregon on September 15, 2020. FEMA may make additional designations after damage assessments are completed in the affected areas. A current list of designated areas is available at www.fema.gov.

The FDIC encouraged banks to work constructively with borrowers experiencing difficulties beyond their control because of damage caused by the wildfires and straight-line winds. Banks that extend repayment terms, restructure existing loans, or ease terms for new loans in a manner consistent with sound banking practices, can contribute to the health of the local community and serve the long-term interests of the lending institution and may receive favorable Community Reinvestment Act consideration for community development loans, investments, and services in support of disaster recovery. The FDIC also will consider regulatory relief from certain filing and publishing requirements.

U.S. households faring better but facing uncertainty
The Federal Reserve Board has reported that data collected to supplement the Board's seventh annual Survey of Household Economics and Decisionmaking showed that U.S. families were faring better financially in July than in April, but many still faced uncertainty regarding layoffs and prospects for returning to work. In July, 77 percent of adults said they were doing at least okay financially, up from 72 percent in early April, and 75 percent in October 2019. This increase is likely due to some people returning to work as well as the availability of assistance programs either from the government or from charitable organizations. A substantial number of families received one or more forms of financial assistance, and the effects of these programs were apparent in people's overall financial well-being and ability to cover expenses.

The July survey demonstrated that people appeared better able to handle small financial emergencies than they were nine months prior in October 2019. Seventy percent of adults said in July that they would be able to pay an unexpected $400 emergency expense entirely by using cash, savings, or a credit card paid off at the next statement—an increase from 63 percent last October.

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