AMLA 3 nd Annual BSA Conference BSA/AML HOT TOPICS October 4, 2013 Christopher Price Senior Compliance Manager, Regulatory Advisory

Introduction and Overview Introduction BSA/AML Hot Topics – Medical Marijuana – Mortgage Lending Other BSA/AML Common Findings

BSA/AML Hot Topics Medical Marijuana – State law vs. federal law – Federal Regulatory expectations – Standard and Enhanced CIP – CDD and EDD – Filing SARs

BSA/AML Hot Topics Mortgage Fraud – Appraisal Fraud Red Flags – Red Flags for Loan Modification Schemes – Reverse Mortgage Fraud – Developing procedures for service personnel off of RESPA servicing amendments – The Case of Louis Gendason – Loan Officer

BSA/AML Hot Topics Other Common BSA/AML Issues – Lack of system validation – Issues with Independent Audit – Risk Assessment is not adequate – Program is not Enterprise Wide – does not cover all areas of the bank

Final BSA/AML Comments & Questions Thank You! Christopher Price Senior Compliance Manager Regulatory Advisory Services FIS Enterprise Governance Risk and Compliance x75039 Office Direct Fax