NBA meets virtually and in DC for visits with Nevada's Senate and House delegates.
NBA works with state legislators during session years and with interim committees in off years. In additional to supporting efforts to promote financial literacy, affordable housing and economic development, we work to ensure Nevada is an environment where banks can provide the best products and services to customers.
Thank you to our GR Committee members for all of your work during session. NBA will be working closely with interim Nevada's legislative committees throughout the second half of 2023 and during 2024.
Scroll down for a copy of the End of Session Report.
Nevada Bankers engage with State and federal regulators regularly. Member feedback is a critical piece of helping regulators with their job of providing effective, safe and meaningful oversight. In addition lt irregular meetings with our State FID, NBA works closely with federal regulataors and also offers members a chance to engage in person during the Fall DC visit.
Q: A new customer of ours does not have a photo ID due to their Amish religion & culture. For CIP purposes, how are we supposed to verify this customer’s identity?
A: While ultimately, this will be a risk-based decision determinate on the bank's own CIP and BSA / AML and CDD policies and procedures, the BSA does allow banks to establish procedures for the required verification of a customer's identity via non-documentary methods, which address those situations in which an individual is unable to present an unexpired government-issued ID, as outlined in 31 CFR 1020.220(a)(2)(ii)(B); these methods may include contacting the customer; independently verifying the customer's identity through the comparison of information provided by the customer with information obtained from a consumer reporting agency, public database, or other source (i.e. verifiable internet resources, for example); checking references with other financial institutions; and obtaining a financial statement. However, in as far as attempting to verify identification via documentary methods, FinCEN offers the following guidance:
"…other forms of identification may be used if they enable the bank to form a reasonable belief that it knows the true identity of the customer. Given the availability of counterfeit and fraudulently obtained documents, a bank is encouraged to review more than a single document to ensure it can form a reasonable belief that it knows the true identity of the customer." FFIEC - Regulatory Requirements for Customer Identification Programs
Essentially, in instances where an unexpired government-issued photo ID is unavailable, it may be appropriate due diligence to ask for two (or more) alternate forms of identification, such as a birth certificate and a social security card, for example. The primary consideration to keep in mind is whether there is enough of a basis in reviewing the obtained documents to form the reasonable belief of knowing the identity of the customer. Again, however, this will ultimately be a risk-based decision that is specified upon the requirements of the bank's established CIP and BSA / AML program and policy.
Compliance Alliance offers a BSA / AML / OFAC Toolkit with a number of additional resources: https://compliancealliance.com/find-a-tool/by-toolkit/bsa-aml-ofac/
Also offers a comprehensive suite of compliance management solutions. To learn how to put them to work for your bank, call (888) 353-3933 or email info@compliancealliance.com and ask for our Membership Team.
Sign Up for a live Compliance Hub demo:
Compliance Alliance Hub for Trust
Trust Tools for Compliance is a stand-alone program designed specifically to assist and support wealth management divisions and brick-and-mortar money managers with their regulatory compliance needs. To learn more, call (888) 353-3933 or email info@compliancealliance.com and ask for our Membership Team.
Sign Up for a live Compliance Hub Trust Demo.
Compliance Hub for Mortgage
Bankers Alliance now gives you easy access to Mortgage Tools—a collection of proprietary regulatory compliance tools with more than 200 worksheets, checklists, trainings and more & a live hotline chat feature connecting you to attorneys and compliance experts—all designed to safeguard internal operations, strengthen business practices, and develop exam-ready organizations. To learn more, call (888) 353-3933 or email info@compliancealliance.com and ask for our Membership Team.
Sign up for a live Mortgage Demo
Review Alliance – DID YOU KNOW?
Did you know institutions and MLOs must renew their NMLS registrations annually during the renewal period of November 1 through December 31?
Review Alliance, an independent group of compliance specialists offering banks deep-dive audits of their existing transactions, recommendations about program enhancements or guidance on future safety and soundness. In 2020, we added Virtual Compliance Officer - a new shared service-model using bank-dedicated compliance officers; perfect for monitoring and guiding your bank remotely. To learn how to put them to work for your bank, call (833)-683-0701 or email info@bankersalliance.org and ask for our Membership Team.
For timely compliance updates and resources, subscribe to Compliance Alliance’s email newsletters.
Nevada Bankers Association
Nevada Bankers Association 1001 E Sunset Road #96513 Las Vegas, NV 89193 US
Copyright © 2022 Nevada Bankers Association - All Rights Reserved.
Powered by GoDaddy