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Inside TRC

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Thursday, 18 Sep 2014

Have you heard about “Pass it On” from the Federal Trade Commission (FTC)? The Federal Trade Commission’s mission is to prevent business practices that are anti-competitive or deceptive, or unfair to consumers; to enhance informed consumer choice and public understanding of the competitive process; and to accomplish this without unduly burdening legitimate business activity.

In an effort to further their mission, the FTC has created “Pass it On” which provides articles, presentations, video and activities—directed at arming consumers with the knowledge they need to protect themselves and their friends and families. So how does the word get out?

The website contains free publications, such as bookmarks, your staff can hand to their customers to start the conversation. The free presentation materials include subjects such as:

• Identity Theft
• Imposter Scams
• Charity Fraud
• Health Care Scams
• Paying Too Much
• “You’ve Won” Scams

TRC can help you create an informed and knowledgeable staff with products such as First Line of Defense and The Fraud Prevention Series, and the Federal Trade Commission free publications can help you take that message to your customers…for free!

Wednesday, 3 Sep 2014

The FDIC is clarifying its supervisory approach to institutions establishing account relationships with third-party payment processors (TPPPs). In an informational article, the FDIC contained lists of examples of merchant categories associated with higher-risk activity. To some, this created the misperception that these categories were “prohibited or discouraged”!

In fact, it is FDIC's policy that insured institutions that properly manage customer relationships are neither prohibited nor discouraged from providing services to any customer operating in compliance with applicable law. Accordingly, the FDIC is clarifying its guidance to reinforce this approach, and as part of this clarification, the FDIC is removing the lists of examples of merchant categories from its official guidance and informational article.

The complete financial institution letter can be accessed HERE

Keeping your financial institution up to date on regulatory issues and your employees educated can be a daunting task. TRC can help. To learn more, contact us at or (800) 222-9909.

Thursday, 21 Aug 2014

On August 11, 2014 FinCEN issued the following Advisory:

Advisory to U.S. Financial Institutions on Promoting a Culture of Compliance BSA/AML shortcomings have triggered recent civil and criminal enforcement actions — FinCEN seeks to highlight the importance of a strong culture of BSA/AML compliance for senior management, leadership and owners of all financial institutions subject to FinCEN’s regulations regardless of size or industry sector.

While this advisory does not change any existing expectations or obligations toward BSA/AML requirements; nor is it intended to change or otherwise interpret regulatory expectations or obligations that financial institutions may have outside of the BSA. It is, however, designed to specifically emphasize the following:

• Leadership Should Be Engaged
• Compliance Should Not Be Compromised By Revenue Interests
• Information Should Be Shared Throughout the Organization
• Leadership Should Provide Adequate Human and Technological Resources
• The Program Should Be Effective and Tested By an Independent and Competent Party
• Leadership and Staff Should Understand How Their BSA Reports are Used

Understanding and communicating the context and the purpose of FinCEN’s BSA/AML regime is equally important to a financial institution’s culture as understanding its underlying requirements, and financial institutions should consider including such information as part of their ongoing training requirement.

TRC Interactive can help your staff understand the significant importance of the BSA/AML requirements as well as how the information in BSA reports is used. Our BSA training courses are tailored to job description and are supported by additional information requirements including Anti-Money Laundering, USA PATRIOT Act, Customer Identification Program, Suspicious Activity Reporting, and Office of Foreign Assets Control. To learn more, contact us at or (800) 222-9909.

The complete FinCEN advisory is available HERE.

Friday, 8 Aug 2014

The Consumer Financial Protection Bureau (CFPB) proposed a rule to improve information reported about the residential mortgage market. The rule would shed more light on consumers’ access to mortgage credit by updating the reporting requirements of the Home Mortgage Disclosure Act (HMDA) regulations. The Bureau also aims to simplify the reporting process for financial institutions.

HMDA, which was originally enacted in 1975, requires many lenders to report information about the home loans for which they receive applications or that they originate or purchase. The public and regulators can use the information to monitor whether financial institutions are serving the housing needs of their communities and identify possible discriminatory lending patterns.

Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) in 2010 in response to the mortgage market crisis. The Dodd-Frank Act directed the CFPB to expand the HMDA dataset to include additional information about loans that would be helpful to better understand these aspects of the mortgage market.

The Bureau is proposing to improve the quality and type of HMDA data as required by the Dodd-Frank Act. The Bureau is also looking at ways to make submission of data easier for lenders and to improve the user experience in accessing the public data.

To provide better information about residential mortgage credit, the Bureau is proposing changes to the rules that establish what data financial institutions are required to provide. The proposed changes include improving market information and monitoring access to credit.

The CFPB aims to:
• Standardize the reporting threshold
• Ease reporting requirements for some small banks
• Align reporting requirements with industry data standards
• Improve the electronic reporting process
• Improve data access

The proposed rule will be open for public comment through October 22, 2014.

A copy of the proposed rule, which includes information on how to submit comments, is available at:

Keeping your financial institution up to date on regulatory issues and your employees educated can be a daunting task. TRC can help. To learn more, contact us at or (800)222-9909.

Friday, 25 Jul 2014

The Financial Crimes Enforcement Network (FinCEN) is issuing an update to advise financial institutions on the increased use of bold funnel accounts as part of trade-based money laundering conducted by criminal actors following the restrictions on U.S. currency transactions in Mexico. This Advisory provides “red flags” that may assist financial institutions identifying and reporting suspicious funnel account activity.

A “funnel account” is an individual or business account in one geographic area that receives multiple cash deposits, often in amounts below the cash reporting threshold, and from which the funds are withdrawn in a different geographic area with little time elapsing between the deposits and withdrawals.

There are, of course, similar legitimate financial activities. So, no one activity by itself is a clear indication of trade-based money laundering. Financial institutions are encouraged to use previous FinCEN advisories as a reference when evaluating potential red flags.

If your financial institution has suspicion, filing of a Suspicious Activity Report (SAR) may be required. While the transactional activity that U.S. financial institutions may experience as a result of the Mexican restrictions may not be indicative of criminal activity, U.S. financial institutions should consider this activity in conjunction with other information, including transaction volumes and source(s) of funds, when determining whether to file a SAR.

Financial institutions should continue to be alert to the variety of methods that may be used to move funds linked to the laundering of criminal proceeds and to report that information as appropriate. Be alert to a possible connection between the suspicious activity being reported and the enacted U.S. currency restrictions on Mexican financial institutions.

The Advisory is available at:

Keeping your financial institution up to date on regulatory issues and your employees educated can be a daunting task. TRC can help. To learn more, contact us at or (800) 222-9909.

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