MAY/JUNE 2018 | VOL. 39 | NO. 3
12 What’s New
BY MEG SCZYRBA,
BY AM Y DRUSHAL, ESQ.
BY MARGARET L. WEIR,
33 Profiles in
BY ALISON OSHOP
34 From the
BY LESLIE CALLAWAY,
MARK KRUHM, CRCM,
RHONDA CAS TANEDA,
36 Around the
4 What You May Not Know About the Beneficial Ownership Rule
BY CHRIS SIMPKINS, CAMS, CFE
As the required implementation date of May 11, 2018 for
FinCEN’s Customer Due Diligence/Beneficial Ownership rule
creeps ever closer, the process and procedural challenges
that banks may face are becoming more clear. While the
rule initially seemed straightforward, there is more hidden in
the details than there was at first glance. FinCEN published
a second set of FAQs on April 4, 2018, which have been
beneficial in clarifying some of the issues with the rule’s
original challenges. This article addresses some of those
challenges and poses some possible solutions.
14 Identifying and Mitigating Conduct Risk: Is Your Compliance Program
Up to the Challenge?
BY THOMAS W. GRUNDY, CRCM
What can you be doing to provide some degree of assurance
that your CMS goes the distance when it comes to managing
conduct risk? Here you’ll gain insight into the types of
considerations and questions every compliance professional
should be asking to challenge the efficacy of their conduct
risk management compliance program.
22 Reg E Primer: Amending the Error Resolution Process
BY EMILY M. MORRISSEY, CRCM, PAUL R. OSBORNE, CPA, AMLP,
CAMS, AND NIALL K. TWOMEY, CRCM
Over time, many banks have come to view Regulation E
as a deposit regulation with little to no risk. However, this
perspective could prove dangerous in today’s regulatory
environment, where systemic violations of the requirements
could lead to the downgrading of an FI’s overall CMS.
Lookback requirements, which have always been common
for other regulations, are now expanding to include
28 Check Your Watch: It’s Time to Update Your Social
Media Policy Again
BY BARBARA BOCCIA, CRCM
It seems as if social media changes at the speed of light.
Every time policies and procedures are set, technology
advances and it is time to review the plan again. While every
review is different, and guidance may change and evolve, the
following “how to” guide should be helpful for updating your
social media policies.