It’s not enough for your own credit union to be BSA compliant. Now the CFPB expects us to “be our vendors’ keeper” too. Not only must we ensure our own conformity with SAR, CTR, MIP, MTB, and NPI requirements, we must also see that every vendor that serves us conforms as well. Does your outside legal counsel receive members’ NPI? What are their file-security protocols? Have you seen their disaster-recovery plan? Are your email exchanges encrypted? Examiners will ask, and the answers better be “yes.” Come get a 90-minute dose of reality and try for Frank’s class-participation prize of homemade jam.
About the Speaker Debnam Narron Drake Saintsing & Myers since 1994, following a 16 year practice specializing in creditor's rights, bankruptcy, and repossession law in Louisville, Kentucky. There, he was senior vice president of William Mapother's law firm.