* Please note that the recording will not be immediately delivered to you. Upon purchasing please allow 24-48 hours for delivery. The recording will come in the form of a web link via e-mail from [email protected] The training manual that corresponds with the recording will be automatically delivered upon purchasing via email from the website.
Prior to 2011, there was no mention of the adequacy or deficiency of a BSA Model Validation in any examination report, audit report or enforcements action. That year the OCC and the Federal Reserve issued guidance called “Supervisory Guidance on Model Risk Management” and it has become very clear over the last five years that all banks, regardless of size or regulator, which use an automated transaction monitoring system (TMS) are expected to undergo an independent, periodic validation of its monitoring system to ensure that it’s not garbage in, garbage out. Banks now routinely turn this task over to third parties to perform such validations without fully understanding what is expected by regulators and auditors and how to properly scope, and oversee, the validation process.
Your bank needs to show your auditors and regulatory agencies that your TMS software accurately and comprehensively aggregates and monitors transactions of all customers and performs as intended in detecting suspicious activity as well as adequately risk rating, both at account opening and on an ongoing basis, risks associated with the customer relationships.
There were numerous BSA enforcement actions in 2016 and a common theme was the deficiencies, or omissions, concerning bank’s model validation processes and the knowledge base of those that were responsible for overseeing such systems. Most Compliance and BSA personnel deal with laws and regulations rather than algorithms and quantitative analysis and struggle with the concept of how to properly ensure that the TMS is producing the intended results – and, at times, whether the information produced would trigger a SAR. This two-hour recording will provide a level of knowledge that key bank personnel can utilize to oversee the validation process and ensure the bank is meeting regulatory and audit expectations. You’ll also receive a detailed training manual and PowerPoint slides.
Upon completion of the program participants will understand:
- Data validation vs model validation and how they interact;
- Accuracy in risk rating/ranking of relationships and accounts;
- Expectations and format of the validation engagement letter, scope, work-papers and final report;
- Independence considerations for in-house model validations;
- Background and experience of internal or external personnel conducting validation;
- Ensuring that data collected and loaded into the monitoring software is accurate and comprehensive;
- Core, host and other systems that feed into the data stream;
- Corrective action follow-up to any identified deficiencies or gaps;
- Model data input, processing and reporting methodology and expectations;
- Impact upon SARs, CTRs, CDD and EDD;
- System utilization for initial Customer Risk Profile and ongoing monitoring; and
- Differences in Rules Based vs Behavior Based parameters and efficiencies.
This program is designed for personnel in Compliance, Deposit Operations, Branch Administration or other departments that are responsible for reviewing alerts generated by a bank’s transaction monitoring system and for those who are utilizing TMS output information to determine whether to file a SAR or not. Attendees also include BSA Officers, auditors and members of management with BSA oversight responsibilities.