Independent Banker - May 2019 - 21

Next: Boosting SBA success through education
located in smaller communities, personnel
with BSA/AML expertise and
training skills may be scarce. It may
also be cost prohibitive to use outside
trainers for every training session. A
collaborative arrangement may allow
banks to share internal training personnel
or could be used to leverage
the cost of a qualifi ed instructor.
Q BSA/AML officers: Each bank
must designate a qualifi ed individual
to serve as a BSA offi cer, but
the interagency statement does not
recommend banks share BSA offi -
cers unless all banks party to the
agreement are affi liates. " Unfortunately,
sharing the most critical
resource-the BSA/AML offi cer or
professional-remains limited on a
practical basis to the enterprise level
programs that we often see at multibank
holding company groups,
which can operate very eff ectively, "
Bequeaith says.
Preparation is everything
Although BSA/AML responsibilities
rest on many throughout the bank, a
well-prepared BSA/AML offi cer can
make a big diff erence.
" We created the BSA/AML Certifi cation
program for the ICBA in 2007 to
meet the specifi c needs of community
fi nancial institutions and provide the
peer-sharing context that is referenced
in the guidance, " Bequeaith says. " We
do numerous case studies, often grouping
attendees by size, core vendor or
AML-monitoring program, to provide
the forum to discuss best practices.
" For our day at ICBA's Annual Current
Issues/Certifi cation Conference
in the fall [see sidebar], we expand
this peer sharing by posing rigorous
case exercises around technical fi ling,
customer due diligence, transaction
monitoring and suspicious activity
report fi ling, " he adds. " As most of these
programs are attended to capacity, it
appears to be meeting expectations. "
" Reading between the lines, it
appears clear that the regulators have
increasing expectations for BSA at
community banks and don't intend to
allow resource challenges to diminish
their performance. "
-David Bequeaith, TIB-Bequeaith Banking Solutions
While collaborative arrangements
may off er some benefi ts, their use
must be managed to minimize risk
and to ensure the banks that engage
collaboratively benefi t as expected.
Community banks considering the
benefi ts of collaborative arrangements
for sharing BSA/AML resources should
exercise due diligence and weigh these
benefi ts and risks carefully.
Mary Thorson Wright, a former Federal
Reserve examiner, is a financial writer
in Virginia.
      ǫ
Loan Participations Structured for the Community Bank Market
5HY XS \RXU ORDQ SRUWIROLR ZLWK 'RXJKHUW\ )XQGLQJ As a commercial finance
company we service rather than compete with community banks. Our loan
participations are structured for the community bank market and our current
portfolio has been participated to hundreds of community banks nationwide.
Active relationships
with over
community banks
nationwide.
ELOOLRQ
in loans
originated
since 1996.
Over
financings
since 1996.
Loan servicing
portfolio
averaging
ELOOLRQ
Corporate Headquarters: Minneapolis, MN * Ph: 612.317.2000 | 800.227.0786
ZZZGRXJKHUW\PDUNHWVFRP * 5HIHU WR ZHEVLWH IRU OLVWLQJ RI DOO ORFDWLRQV
Independent Banker - May 2019

Table of Contents for the Digital Edition of Independent Banker - May 2019
