And Then Comes Christmas

By Barbara E. Hurst

You may have noticed this issue is a little late getting to you. And I do heartily apologize for it. During the middle part of the summer, there wasn't much news to report and I didn't want to simply fill an issue with fluff. So we concentrated on the workshop and four new training videos. However, doing the job you do, I know you understand how you can just get so piled up with work that time slips away without all the things getting done that need to be done.

We got caught in the crunch of updating videos and making new ones because of all the changes in regulations and laws. And preparing for the Security Officer's Workshop that was just held in Philadelphia - where we had record numbers this year. The PATRIOT Act and all the changes that go with it needed a lot of attention and translation and updating. Drop in a vacation or two and schedules went into overload. It started to remind me of the time I spent at my job at the bank when I was constantly saying, "Sure - I can do that." But there I had staff behind me that I could delegate it to and they would do it! That's perhaps the one part about my old job as a banker that I miss!

The Security Officers Workshop was one of the best we've had. It was highlighted by the session on the PATRIOT Act on Wednesday by David Gilles from FinCEN and John Byrne from the ABA talking about the final rules that were due out momentarily on the USA Patriot Act of 2001 (often referred to these days as the PatAct) sections 313, 314, 319 and 352. While John was talking about what they sort of expected the final rule to be, his office sent him a FAX that was delivered to him while he was speaking, giving him exactly that information. You just can't get updates much more current than that!

Each year I rack my brain to second guess what's going to be hot by the time the Workshop rolls around, and it's gratifying to get the subjects and speakers on target. This was one of those years. All ten of our banking and legal experts were just what we needed.

We're also working hard completing the videos that will help with your training. Some are fun to write and make - like the ones we did on Orientation and the Bank Secrecy Act. Others, like the training for Regulation DD, are a lot tougher to make interesting. But we think we did it. I'm sure you'll let us know! And you know when something really big and important hits your desk, you have to drop everything else and do it. So you'll understand that we're waiting for the final rule on 326 of the PatAct so that we can get the training video on the changes to you. It's all done except for the final rule. No clever name on that video. It's just called "The USA Patriot Act of 2001." We thought about naming it The Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, but figured we better not! Nobody would know what we were talking about!

I'm afraid that once we get the final rule on 326 of the PatAct, you'll find you're putting in the overtime hours too, trying to get everything done that has to be done. There is no way you can possibly meet the requirements of the rule the way it is now. For instance, the changes in new account opening and verification go into effect October 26, 2002 - the day they are supposed to issue the final rule! Not possible. You'll have training of front line to do, new forms to create, new verification procedures to write and teach. Keep an eye on www.BankersOnline.com. There are sample Customer Identification Programs (CIP) on there (they will be required by every financial institution), and new accounts forms in the Bankers Tools section. You'll need all the help you can get to meet the deadline date - even if it's extended when the final rule is announced. Please realize the examiners are already gearing up for compliance procedures. And, of course, we'll be here to help.

So by the time we get into December, I should be caught up, and so (hopefully) will you.

And then comes Christmas...

Copyright © 2002 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 12, No. 7, 9/02