Federal Advocacy
NBA meets virtually and in DC for visits with Nevada's Senate and House delegates.
State of Nevada
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.
Regulatory
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.
Compliance Alliance
Compliance Alliance Question of the Week
Q: Where should we include victim details – such as an entity’s authorized signatories or contact persons – within a Suspicious Activity Report?
A: Generally speaking, the SAR Filing Instructions and SAR Narrative Guidance Package instruct that information about the victim should generally only be included in the narrative, and only if that inclusion is necessary for a complete description / understanding of the suspicious activity; indeed, the intention of the SAR is to capture information about the suspicious activity, and in particular, the "subject" of that activity (i.e. the person or entity conducting, attempting to conduct, or suspected of being involved in the suspicious activity):
"Provide information on the victims of the suspicious activity only when it is necessary for a complete understanding of the activity. DO NOT record victim information in a Part I Subject Information record." FinCEN Suspicious Activity Report (FinCEN SAR) Electronic Filing Requirements, pg. 179
Broadly, this suggests that if the bank absolutely needed to include information on a victim that was a business, then the contact persons (or, for example, signatories / authorized signers) information being listed would only be appropriate if that information was necessary to fully understand the suspicious activity being described (for reference, generally, please see: FFIEC - Suspicious Activity Reporting).
Given the subjective nature of SAR narratives - ultimately, this is a risk-based determination reliant on the bank's own BSA / AML policies and procedures, but the guidance suggests that this information may likely only be appropriate when absolutely crucial. As always, our BSA / AML / OFAC Toolkit contains a bevvy of resources on the subject (in particular, our BSA SAR Form and Narrative Cheat Sheet.)
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 that a closed-end mortgage loan or open-end line of credit that is primarily for a business or commercial purpose is HMDA reportable if it meets the definition of a home improvement loan, home purchase loan, or a refinancing?
- For example, a closed-end mortgage loan to improve an attorney’s office that is located in her single-family dwelling is reportable.
- See Comment for 1003.3, 3(c)(10)-3
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.
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