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Compliance Officers - Caught Between a Rock and a Hard Place
 Reconciling Examiners' Increased Expectations with Your Board's Perception of Compliance Risk
By Lori Moore, CRCM, Director of Compliance
The financial meltdown that began to surface in 2008 is at the root of another topic ripe for discussion, the increased need for and importance of a sound and thorough compliance risk program. Two groups were particularly taken to task for allegedly falling asleep at the wheel in the run up to 2008 – federal regulators and financial institution boards. Although in most cases, the criticism leveled was the guilt of omission rather than commission, the general perception is that their laxity in oversight, while not the only cause, certainly created an environment where risk was tolerated more than was prudent. Both remain in the spotlight today to see how they will handle the era after the Great Recession. Will they be able to protect and prevent individual institutions and the system as a whole from a repeat meltdown? During the heat of the crisis and up until recently, credit and liquidity risks took center stage in the battle to prevent a recurrence. With those risks now generally stabilized, compliance risk is reemerging as a key focal point, at least for federal regulators. Boards may or may not have caught up which can leave compliance officers caught between a rock and a hard place.
OFAC 101: Does Your Company Play By the Rules?
Complying with OFAC is more complex than ever before. Do you have a comprehensive understanding of the term “OFAC Compliance” and how it impacts your industry?
Attend this webinar and learn more about:
- The history of OFAC since September 11
- The responsibilities you have as a company to comply with OFAC regulations
- How you can avoid expensive penalties and fines as a result of OFAC violations
Speaker:
Lori Moore, CRCM
Director of Compliance
ATTUS Technologies
11/18/2010 3:00PM to 4:00PM ET
 Question: How do you get the ODFI to include the customer's name on POPs and ARCs? They will only give us an account number but we need the name as well. This would speed the processing and we would not have to return the item due to not being able to verify the customer.
Answer: I'm not sure that the originator can include the name on an ARC or a POP. These are entries where the merchant uses the check to capture the routing and account number as well as the check number and dollar amount only so it can be initiated. I don't think there is any opportunity to enter the name. However, I realize this can be a matter of customer service but you are permitted to post the item by account number only. And, the ODFI must make good on it.
Got a question on a tricky regulation? We want to hear from you. Submit your question and an expert will answer it in a future issue.
ID Theft: SSN is 'Key to the Kingdom'
Incidents Prove Link Between Social Security Numbers, ID Theft
By Tracy Kitten, govinfosecurity.com
The Colorado Supreme Court decision to reverse a conviction for criminal impersonation has stirred debate among identity theft protection advocates. In short, advocates say the Oct. 25 ruling sets a precedent that provides a loophole for those who impersonate others by stealing and/or misusing Social Security numbers.
"The Social Security number is the key to the kingdom of almost every type of identity theft," says attorney and certified information privacy expert Mari Frank. "It's the key to medical-benefit theft, government-benefit theft, you name it. This case, I think, sets a very bad precedent," she says, "because there are a number of people with bad credit or a criminal record or even illegal immigrants in this country that would use a stolen Social Security number to get a job, take out a car loan or get other benefits."
Just For Financial Institutions
For additional FFIEC guidance, the site www.ffiecguru.com is a resource just for financial institutions. The site is designed to keep you informed of current auditor and examiner trends, as well as the latest FFIEC updates. Please visit the discussion board for answers to your compliance questions or to chat with other financial institutions. It also supports RSS feeds.
The site was developed and maintained by our trusted partner, Safe Systems, a national leader in providing compliance-centric IT solutions for financial institutions exclusively. The guru is the Safe Systems' Director of Compliance, Tom Hinkel.
Confessions of a First-Time Boss: An Apology
By Roberta Chinsky Matuson, bnet.com
Lately I’ve been thinking about everyone who used to work for me, in particular those of you who were my first direct reports. I’ve spent the last year writing a book for new managers, Suddenly in Charge: Managing Up, Managing Down, Succeeding All Around, and I’ve had plenty of time to reflect on what it must have been like to work for me early in my career. I realize that at the ripe old age of 24 (can you believe they made me HR director?), I may not have been as strong a leader as I thought. I owe you all an apology. In making amends, I hope that others will learn from my past mistakes and limit the damage that so often occurs when we think we know it all simply because we’ve been given a title.
A day doesn’t go by when I don’t think about our time together as a team. My intentions were good, but my nerves, ego and lack of experience got in the way of becoming the type of boss you deserved. Please accept my apologies for...
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