Author Archives: Jonathan Ferguson

Figuring Out What to Say and How to Say It to the Board of Directors is Like Balancing on a Bicycle

“Life is like riding a bicycle. To keep your balance, you must keep moving.” -Albert Einstein Successfully riding a bike to get where you want to go requires patience, knowledge, and experience. Determining what to say to your board of directors is like learning how to balance on a bicycle. The “what to say” is like leaning and pedaling on a bike. If you lean too far to one side or the other, you’ll fall off. If you pedal too slow, you won’t go anywhere; Continue reading →

Three BSA/AML Errors to Avoid

Bank Secrecy Act and Anti-money Laundering (BSA/AML) enforcement is shaping up to be a hot compliance topic this year. We’ve heard from the NCUA that one of its supervisory priorities for 2018 will be BSA compliance. There are also some big changes coming in just a few months with FinCEN’s new customer due diligence and beneficial ownership requirements. What all this means is that you’ll want to pay particularly close attention to your BSA/AML program and procedures throughout 2018. To ensure your AML program is Continue reading →

The Top 5 Posts of 2017

2017 is now gone, but it’s always worth a look back to see where you’ve been. Here’s a look at the top 5 most popular AdvisX blog posts of 2017. 1. The Elephant in the Room: Fair Lending Regression Analysis We’ve all heard the expression, “how do you eat an elephant? One bite at a time.” The inventor of this phrase must have been marooned and starving on an elephant-infested island, because seeing an elephant and wondering, “how am I going to eat that thing?” is Continue reading →

Front-to-Back AML Validation: How to Envision What You May Be Missing

Originally published on CUInsight.com For those of us who experienced a partial loss of vision at a relatively young age, we likely remember the day that we learned we needed glasses. The process typically began with an elementary school teacher who noticed our permanent squint at the chalkboard. Before we knew it, we were sent to the school nurse for a primitive eye exam consisting of a few “E’s” in all of their assorted directions. Failing that, we were sent home with a note to Continue reading →

AML System Assembly: Don’t Ditch the Instruction Booklet

Whether it was a model airplane, some Legos, or a Swedish bookcase, odds are you’ve purchased something that requires some at-home assembly. What all these things have in common is the instruction booklet. Not all of these instruction booklets are created equal, however. Some are clear, precise and easy to follow, while others are so vague and complicated that trying to decipher them often results in pulling out your own hair and a few choice curse words. At one point or another, you may have Continue reading →

New York’s 504: BSA/AML Requirements You May Want to Start Wearing

If you’re a fashion fanatic and you want to get a jump on what will be hot next season, you’d probably want to look to the current fashion trends in New York. After all, New York, New York is known as one of the fashion capitals of the world. Now, if you’re in charge of BSA/AML compliance at your financial institution, your regulators will not be amused if you’re behind on anti-money laundering efforts, even if your compliance team looks ready to walk the runway. They’ll Continue reading →

BSA Compliance: The Dangers of Letting it Get Too Ordinary

Humans have a remarkable ability to get used to things. For example, on a trip to Yellowstone National Park several years ago, I saw a group of people excitedly pointing to something off in the distance. They had cameras out and were acting as if they were seeing Sasquatch. However, when I got close enough to see what they saw, I realized it was only a few mule deer. The people admiring the deer, it turned out, were from a large urban city outside of the United Continue reading →

Comparative File Review: See the Whole Iceberg

It’s common knowledge that the part of an iceberg that can be seen above the surface is just a small portion of the whole iceberg. In fact, about 90 percent of the iceberg is hidden below the water’s surface. If you are trusting your fair lending risk to just the data visible on the surface, there is a lot that you’ll miss. In our last post, we described how a regression analysis can be used to see more of your data that is hidden below the Continue reading →

The Elephant in the Room: Fair Lending Regression Analysis

We’ve all heard the expression, “how do you eat an elephant? One bite at a time.” The inventor of this phrase must have been marooned and starving on an elephant-infested island, because seeing an elephant and wondering, “how am I going to eat that thing?” is not exactly a normal reaction. Even an avid steak-eater likely doesn’t see a cow and immediately wonder how to eat it. But however it happened, someone noticed that attempting to eat the world’s largest land animal in one go Continue reading →

The Top 5 Posts of 2016

2016 is just about gone, but there’s still just enough time to look back and see where we’ve been. Here’s a look back at the top 5 most popular blog posts of 2016. 1. FinCEN’s Top 3 Money Laundering Concerns The fight against money laundering and terrorist financing in the U.S. is an ongoing and evolving battle. That’s why every year FinCEN produces a new National Money Laundering Risk Assessment from the Department of the Treasury. In an analysis of more than 5,000 law enforcement cases and Continue reading →