Compliance Review Programs

The Outsource Program

The Outsource Program is our flagship and most popular offering. The Outsource Program provides the institution with the tools and resources to effectively outsource the administration of the compliance function. It includes the following elements for an effective compliance program:

• Policy and procedures development and perpetual updates
• Risk-focused testing of both lending and deposit transactions
• On-site training
• Year-round phone and e-mail support

Bank Secrecy Act/Anti-Money Laundering Regulation Reviews

The Bank Secrecy Act/Anti-Money Laundering Review is designed to provide Management with an independent assessment or audit of the Bank Secrecy Act compliance laws and regulations described below.

In conducting the BSA Review, BFG utilizes a risk-based approach to perform a focused, yet comprehensive review of an institution’s compliance with the BSA laws and regulations.

The review is designed to assess the level of the institution’s compliance performance and the effectiveness of current compliance policies, operating procedures and employee training programs. Early detection of regulatory violations, deviations from established policies or deficiencies in operating procedures is crucial to minimizing the potential risk of regulatory criticism and consumer litigation. In addition, as a result of the compliance review, Management is provided with an objective evaluation of overall compliance performance, which can assist in budgeting for or reallocating human resources and fiscal dollars.

The comprehensive review emphasizes substantive, procedural and technical compliance with the BSA laws and regulations and is designed to assist Management monitor the effectiveness of day-to-day compliance efforts. BFG consultants help to identify the underlying cause of the violation or error and work with Management to implement procedural changes to prevent recurrence.

Compliance with the following areas will be tested:

• Bank Secrecy Act Policy
• Currency Transaction Reports & Exemptions
• Monetary Instrument Log
• Wire Transfers
• Office of Foreign Asset Control (OFAC)
• Section 314(a) Requests
• Suspicious Activity Reports
• Customer Identification Procedures
• High Risk Account Identification and Account Monitoring

Fair Lending Reviews

BFG will conduct a side-by-side comparative file analysis based upon an evaluation of the Bank’s fair lending policies, procedures and practices. The Fair Lending Review is designed to provide the Board of Directors and Senior Management with a “self-analysis” regarding fair lending performance. This objective is accomplished primarily by comparing applicant qualifications and characteristics with the underwriting criteria used by the Bank to make the credit decision and the loan terms and conditions offered by the Bank to creditworthy borrowers.

BFG utilizes the fair lending review procedures similar to those currently used by the federal bank regulatory agencies, i.e., FFIEC Fair Lending Examination Procedures. An “underwriting” analysis and “terms and conditions” analysis will be performed on samples of “target” and “control” group applications.

Specifically, BFG will review:

• The Bank’s Loan Policies, underwriting guidelines and lending practices for the specific loan types reviewed by comparative analysis;
• Written complaints received by the Bank alleging discrimination and Management’s responses to those complaints;
• Both internal and external training activities regarding fair lending/nondiscrimination; and
• Denied and approved loan applications based on the scoping guidelines and sample size criteria set forth by the FFIEC.

Annual Review

Provides the institution with a risk-focused annual review of both lending and deposit transactions. The findings and recommendations are presented in a comprehensive written report that is viewed as a management tool.

De Novo Program

Specifically developed to address the needs of de novo banks. The program contains elements of the Outsource Program with further refinements including:

• Initial development and thereafter supporting of the “Compliance Policies and Procedures Manual” for the bank
• Conducting compliance training sessions for bank management and employees
• Performing consumer compliance reviews
• Establishing a compliance management program

Top