Establishing good relationships with examiners is essential when fulfilling Bank Secrecy Act (BSA) compliance obligations, four BSA compliance practitioners agreed during a panel discussion Monday at the CUNA BSA Conference.
Panel participants addressed a variety BSA issues, including elder abuse and the need for talented compliance staff.
The panel featured:
Fleury, a former state banking regulator, stressed the importance of hiring top-notch BSA compliance staff. “This is not a game—this is certainly a safety and soundness issue.”
He asked the room of 300 attendees, “How many of you are knowingly noncompliant? None, right? We are all trying to get this done.”
Fleury and other panelists underscored the importance of being clear to examiners that your credit union is earnestly working to comply with all BSA requirements.
Bailey added that it’s important to interact with examiners to help them understand your compliance information and practices.
Elder financial abuse received significant attention during the panel discussion. Bailey noted that the treatment of this issue varies widely from state to state, and many attendees expressed frustration with lax state laws or standards.
In Iowa, for example, the victim “must be physically and financially reliant on a person’s care” to meet the threshold for abuse, Bailey says. “Anything below that? Nothing.”
To determine instances of elder financial abuse, credit unions need to know an individual’s normal pattern of financial activity.
“You need a system to alert you to unusual activity,” Berg says.
“Everyone has had issues with elder financial abuse, and I was displeased by the threshold for when we could step in [in New Hampshire],” Fleury says. “We had to really push to get someone interested in a case we knew were victims.”
“It would be nice to see some universal standards,” Bailey adds.
The CUNA BSA Conference, held in partnership with the National Association of State Credit Union Supervisors, concludes Wednesday in San Antonio.