On June 30, 2016, the New York State Department of Financial Services (“NYS DFS”) issued the final version Rule 504, “Banking Division Transaction Monitoring and Filtering Program Requirements and Certifications.”  The Rule takes effect on January 1, 2017, with the first reporting date of April 15, 2018.  In a sense, the Rule follows upon the […]
It’s that time of year, scheduling the independent review. You call your provider, discuss available dates for the onsite visit and request the proposal of a new provider or if your provider is returning, the engagement letter. The proposal or engagement letter will outline the who, why, what, when, and where, much like we see […]
On June 30, 2016, the New York State Department of Financial Services (“NYS DFS”) issued the final version Rule 504, “Banking Division Transaction Monitoring and Filtering Program Requirements and Certifications.”  The Rule takes effect on January 1, 2017, with the first reporting date of April 15, 2018.  In a sense, the Rule follows upon the […]
Introduction Independent verification and validation, IVV, model validation, validation or; as Shakespeare might say, a validation by any other name is still a validation. Regardless of the name it has evolved and been redefined over time. Â This article will cover the origin, OCC guidance, regulatory pressure, IVV methodology, reporting, independence, and vendor due diligence in […]
In order to stay compliant with today’s financial standards, most banks utilize some type of anti-money laundering (AML) program, which includes software. These programs follow BSA, OFAC, CDD/KYC, and FinCEN 314(a) guidelines to make sure banks are following AML compliance laws on a daily basis. It’s necessary to review the software and governance program involved […]
