There is a regulatory expectation to perform customer due diligence (CDD) on all high risk customers such as independent ATM owners, non-profit organizations (NPOs) and politically exposed persons (PEPs).
One banker commented “Reg E hasn’t changed, so what’s to learn?” While the Reg itself and the commentary haven’t changed, interpretations of who is a financial institution, what is an error and who has to investigate those errors have.
When your bank receives a claim that an ACH charge to a customer’s account was unauthorized, you have to respond correctly and your customer expects swift results.
Mistakes are bad, except when you learn from them. Mistakes are great when you learn from someone else’s. Join me as we look at what examiners and auditors are finding wrong in banks so they do not find these in your bank.
You shouldn’t be faulted just because, “you don’t know, what you don’t know.” But you will be because you should know. When in compliance, you are responsible for ALL of the compliance changes, updates and guidance issued in 2021.