Just the FAQs — FinCEN’s Guidance on Beneficial Ownership and Cu


Presented by:
John Burnett

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Experienced bank compliance officers know to study a regulator's Official Interpretations, sometimes referred to as "Official Staff Commentary" or simply "Commentary," to find valuable - and legally enforceable - interpretations of regulatory provisions. Oftentimes, the Commentary is more extensive than the regulatory text itself, offering examples to illustrate how the regulator wants a provision interpreted or applied.

FinCEN, however, doesn't publish Official Interpretations as supplements to its regulations. Instead, it releases the occasional Guidance document, often in the form of a curated list of Frequently Asked Questions or FAQs, in some cases (we suspect) internally developed to anticipate and address parts of a rule that are expected to generate questions from those subject to a regulation, and in other cases to publish a settled and approved response to a question that has actually been asked frequently. FinCEN's May 2016 Customer Due Diligence Requirements for Financial Institutions rule clearly raised a lot of questions from bankers. Questions about its impact on CTR filing, relationship to 314(a) inquiries, OFAC checks. Questions about definitions, layers of ownership, ownership by trusts … the list goes on.

In this timely two-hour webinar, Brian Crow and John Burnett will analyze FinCEN's two-part guidance and its 63 frequently asked questions to help you make certain you understand the implications of the answers for your institution's implementation of the new regulatory provisions that have to be complied with by May 11, 2018.

Brian and John will cover all 63 of the FAQs to cover these and other issues:
  • The date by which financial institutions have to comply
  • Effect of the rule on future 314(a) searches
  • Use of the "Appendix A" form
  • Legal entity customer: Is it or isn't it?
  • New accounts and established customers
  • Rollovers and renewals: New accounts or not?
  • Unincorporated associations
  • The "exempt lists"-customers and accounts
  • Existing accounts
  • Accounts that aren't deposits or loans
  • The "control prong"
  • When to collect the information
  • "Drilling down"
BSA Officers, compliance officers and others responsible for ensuring compliance with FinCEN's customer due diligence and beneficial ownership rules.

About the Speakers: John Burnett is a 1979 alumnus of the ABA National Compliance School, and served on its faculty for several years. He graduated with honors with the Class of 1990 from ABA's Stonier Graduate School of Banking. He is also a graduate of the BAI's and the Massachusetts Banker Association's School of Banking.

He joined Cape Cod Bank and Trust Company in 1971 and assumed his role as Compliance Officer in 1976. He also served as corporate secretary and secretary of CCBT's Board of Directors, as well as Clerk of the bank's holding company. John joined Glia Group, Inc., and became a part of the BOL Team in June, 2004.

Mr. Burnett is a former member chair of the Massachusetts Bankers Association Legal and Regulatory Compliance Committee, and of the American Bankers Association Compliance Executive Committee and NCS/NGCS Advisory Board. He served on ABA's Truth in Savings Task Force, and has served on several ABA and Massachusetts Bankers seminar panels.

Brian Crow is Executive Vice President at Thomas Compliance Associates, Inc. in Chicago, IL. Brian brings 20 years of prior banking experience to the consulting field. He was most recently Assistant Vice President and BSA Administrator for a suburban Chicago bank, where his responsibilities included preparing the bank's annual BSA risk assessment and audit documentation. Earlier as Operations Officer at the same bank, Brian monitored AML activity, aided in the implementation of the bank's AML software, and designed the bank's authentication blocking program that helped to reduce debit card fraud losses by 95 percent. Brian's responsibilities also included managing the bank's Regulation E claims, managing the bank's courtesy overdraft program, reviewing Reg CC hold notices for accuracy, and processing claims for fraudulent signatures and endorsements.

Mr. Crow has been, and continues to be, an education consultant for BOL Learning Connect, conducting webinars that have covered VISA/MasterCard chargebacks, debit card compliance and fraud prevention for hundreds of banks. It was in this role that Mr. Crow was recognized as a Bankers Online Guru in 2011.

Like many of us, Mr. Crow began his banking career as a teller, working his way up to head teller and then branch management responsibilities. He earned a B.A. degree in Theology from Concordia University, River Forest, Illinois. Because of his education background, Brian has been given the unofficial title of "Security Evangelist" as he strives to help financial institutions protect their bottom line from losses related to fraud.

This program was recorded in its entirety in April 2018. The CD-ROM includes program slides, materials (if available) and follow-up Q & A document.

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  • Model: cd_faq0418
  • Manufactured by: Glia Group, Inc.

This product was added to our catalog on Friday 06 April, 2018.

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