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Inside TRC

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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that receives multiple cash deposits, often in amounts below the cash reporting threshold, and from which the funds are withdrawn in a different geographic area with little time elapsing between the deposits and withdrawals.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: http://www.fincen.gov/statutes_regs/guidance/pdf/FIN-2014-A005.pdf

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 info@trcinteractive.com or (800) 222-9909.

Wednesday, 9 Jul 2014

Bureau Interpretive Rule Clears the Way for Heirs to Take Over Mortgages When Loved Ones Die

Washington, D.C. – Today, the Consumer Financial Protection Bureau (CFPB) is issuing an interpretive rule to clarify that when a borrower dies, the name of the borrower’s heir generally may be added to the mortgage without triggering the Bureau’s Ability-to-Repay rule. This clarification will help surviving family members who acquire title to a property to take over their loved one’s mortgage, and to be considered for a loan workout, if necessary, to keep their home.

“Losing a loved one should not mean also losing your home. Today’s interpretive rule makes it clear that when family members inherit property, they can take over the mortgage without jumping through unnecessary hoops,” said CFPB Director Richard Cordray. “This gives heirs an opportunity to work with the lender to pay off the loan or seek a loan modification.”

The interpretive rule is available at: http://files.consumerfinance.gov/f/201407_cfpb_bulletin_mortgage-lending-rules_successors.pdf

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 info@trcinteractive.com or (800) 222-9909.

Wednesday, 25 Jun 2014

A recent article in BAI Banking Strategies indicated that a new report by the Center for Financial Services Innovation reveals that ten percent of consumers using a smartphone to deposit a check had it returned to the originating institution due to fraud -- a rate more than double that of other check-cashing methods.

According to the article, the fraud schemes most commonly involved going to a check-cashing outlet right after depositing the same check via smartphone. Mobile deposit leaves the actual check in the hands of the customer and creates the potential for this type of fraud. It has been suggested that one potential step to help eliminate at least some of this fraud would be to require a restrictive endorsement on any check that is sent via a smartphone for deposit.

For example, a financial institution would only accept checks sent for mobile deposit that contained the restrictive endorsement “Deposit via Mobile” or “Deposit sent by Phone” below the customer’s endorsement.

This would certainly not stop all fraud but could serve as a deterrent to some potentially fraudulent situations. For instance, a check presented to a check-cashing store, which has an erasure or blacked out information below the endorsement is going to raise suspicions.

To help keep your staff aware of the most recent fraud trends First Line of Defense provides “real life” transaction training. Keeping your financial institution up to date on issues such as these and your employees educated can be a daunting task. TRC can help. To learn more, contact us at info@trcinteractive.com or (800) 222-9909.

Wednesday, 18 Jun 2014

... at least according to a recent article by Bank Innovation. A recent survey indicates customers are NOT getting the guidance and advice they would like!

“More than half of bank customers in the U.S. — 51% — WANT their banks to proactively recommend services and products, according to the 2014 North America Consumer Digital Banking Survey from Accenture, which was recently released. Yet 70% of the more than 4,000 customers surveyed consider their bank relationship merely transactional!

One of the problems is that the financial service industry loves “initiatives”, which in most cases is a short-lived push to “create a sales culture.” Then, since it’s not properly initiated, trained, coached, incented, or supported, it gradually slides back to the routine where people defend “servicing”, and sales is again a dirty word!

Most of your customers WANT and NEED your expertise. Your staff actually enjoys helping. So why isn’t it working? Learn more about ALL the components of change and delivering the right message by contacting TRC Interactive today. Learn about TRC’s The Customer Experience and how you can be guided to a total, successful, sales initiative that results in, (here’s those words again) a sales culture!

To stay up to date on financial institution trends and news, frequently visit our blog. TRC Interactive also offers online, interactive training on various compliance related topics. To learn more, contact us at info@trcinteractive.com or (800)222-9909.

Wednesday, 4 Jun 2014

Answer this honesty…
Regulators walk in and ask to see your written Identity Theft Prevention Program. Are you nervous at all? If you are, put it on the top of your priority list.

With the recent retail breaches, identity theft has, once again, taken center stage. A very important aspect of an Identity Theft Prevention Program includes ensuring the ITPP is UPDATED periodically to reflect any changes in risk to your customers and your institution. Now is a very good time to review your program and update it as necessary. Because of recent breaches, anticipate that regulatory scrutiny of ITPP’s is likely to increase.

Equally important is training your staff on Identity Theft Red Flags to enhance and include the addition of the knowledgeable staff scrutiny to your already established ITPP. TRC provides solutions to help your staff become knowledgeable and confident in the fight against the crime of identity theft.

With all the new regulations and new issues arising weekly, it is important to remember to update training on existing rules and regulations. We do!

To stay up to date on regulatory trends and news, frequently visit our blog. TRC Interactive also offers online, interactive training on various compliance related topics. To learn more, contact us at info@trcinteractive.com or (800) 222-9909.

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