Posted by Anthony Demangone
Here are a few things that have been rattling around my in-box recently.
- A criminal BSA prosecution against a bank. You don't see this very often. Someone asks me every so often what has to happen for the government to use this power under the Bank Secrecy Act. This is a good example. This could be a good item to share in a training session to underscore that criminal prosecution is a real possibility. However, it is usually used against an organization or official who uses their position to inentially evade the Bank Secrecy Act's requirements. Here's a taste of what the bank allegedly did:
It was further part of the conspiracy that (the bank) opened multiple accounts held in the names of nominees or other business entities so that the cash deposits, on any one day in excess of $10,000, could be deposited into the various accounts, in order to conceal the relationship between the transactions and the depositors and to avoid the filing of any reports. Emphasis added.
The IRS is starting a pilot program to allow those who file IRS information returns to truncate the individual's 9-digit identifying number on paper payee statements. It looks like the pilot program is limited to 1098s, 1099s and 5498s.
NCUA issues Regulatory Alert 09-RA-14 to highlight recent changes to Reg CC and how those changes might affect your funds availability policy.
NCUA issues Regulatory Alert 09-RA-13 to highlight changes to the annual fee threshold for HOEPA loans under 12 C.F.R. Part 226.32. The dollar threshold will drop from $583 to $579, effective January 1, 2010.