TIAA-CREF Trust Company, FSB,
On June 28, 2013, the Office of the Comptroller of the Currency issued a Consent Cease and Desist Order to TIAA-CREF Trust Company, FSB, St. Louis, Missouri (Bank).
The Bank is a federally chartered savings bank with its only office located in St. Louis, Missouri. Its FDIC-reported financials for March 31, 2013, show a 236% growth in total assets over March 31, 2012 ($681 million to $2287 million), and a growth in staffing from 74 to 105 FTEs. The company was established in 1998.
The C&D Order has several articles requiring the bank's board to ensure it has competent management, a viable strategic plan, a capital plan, and improved management of its liquidity, funding concentration, interest rate risk and information security. Several articles, however, focus on BSA/AML concerns, requiring the bank to develop of put into place—
- a comprehensive BSA action plan
- a BSA risk assessment
- BSA independent testing
- BSA internal controls and high risk identification
- CDD and EDD information gathering
- a written program to ensure compliance with SAR filing requirements
- BSA training
- appropriate BSA compliance department staffing