Last Minute Training Tips for BO and CDD

Recorded on April 27, 2018   |   With Mary Beth Guard and Brian Crow

Last Minute Training Tips for BO and CDD

With Mary Beth Guard and Brian Crow
  • 1 Video
  • 2.0 hrs
Course description

After years of discussion and anticipation, the Beneficial Owner/Customer Due Diligence rule is a reality that every frontline employee of a financial institution will need to deal with. And on April 3, 2018, FinCEN issued its much-anticipated guidance to definitively answer some of the lingering questions about what to do and how to do it. You have trained your staff, you’ve modified your procedures, but this rule is a big game changer, filled with new terminology, new requirements, new customer relations challenges, and only now, with the newest FinCEN issuance do we have all of the puzzle pieces. This program provides strategies and tips for reframing and reinforcing what bank staffers need to know and do under the rule and all FinCEN FAQs.

This is a Train the Trainer program. Whether you're the in-house trainer, BSA officer, or in charge of all compliance matters, this webinar will arm you with key tactics for breaking down the complex concepts for your frontline and ensuring consistent, compliant implementation. Recognizing that this affects various departments within your institution, we will provide guidance about the nuances that come into play and how your approach should differ for the different business units - deposits, loans, safe deposit rentals. You'll get charts and quick reference guides to help your staffers take a consistent, methodical approach to compliance.

Perhaps you have already conducted bank-wide training on the new rule – but you didn’t know what you couldn’t know, the answers only FinCEN could give, and those were just released April 3, 2018, 23 months into your two year implementation timeline! Our experience shows us that employees absorb the information in layers, piece by piece. We’ll help you deliver all the pieces. Rather than simply hitting “replay” to tell them what you already told them, our program will equip you with a fresh set of explanations, illustrations, examples, even scripts, to get you out of the box.

This program will provide training tips for every aspect of the rule, including:

  • Important definitions
  • Why the rule was adopted
  • Consequences of noncompliance
  • When the rule is applicable
  • To which customers the rule applies
  • How to talk to the customer about the new requirements
  • Questions customers are likely to ask - and the answers to them
  • Understanding the two prongs: ownership and control
  • What information must be obtained
  • Explaining the "direct or indirect" test for beneficial ownership
  • All about the certification
  • The bank's responsibility vs. the responsibility of the person opening the account
  • How this is different from CIP; how it is similar
  • Verification of identity
  • When you can't proceed
  • The effect of not having an "existing customer" exception
  • If your bank has set stricter requirements than the rule (such as a lower threshold for beneficial ownership)
  • Common misconceptions to avoid
  • What happens when an automatically renewable CD renews
  • What’s the impact of the rule on loan renewals?
  • Close-in-time new accounts and your responsibilities
  • What you need to know about risk-related triggers
  • When re-certification of beneficial ownership is required

<b>Who should attend: </b>
This program is designed for in-house trainers, BSA officers, compliance officers who are responsible for doing training and/or ensuring compliance with FinCEN's Beneficial Owner/Customer Due Diligence rule.

Course Curriculum

Last Minute Training Tips for BO and CDD
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Mary Beth Guard and  Brian Crow
Mary Beth Guard and Brian Crow

Mary Beth Guard is one of the four co-founders of BankersOnline and is now Editor Emeritus, after more than 16 years of serving as Executive Editor. She was instrumental in the creation and expansion of BankersOnline, as well as the launch more than a decade ago of BOL Conferences, Inc. and its continued operation and growth. Mary Beth is also the director of, the premier subscription-based compliance service now being offered online. Also, Mary Beth serves as CEO of Glia Group, Inc., which produces BOL Learning Connect. For more than three decades, Mary Beth has utilized her background as an attorney to focus on banking industry issues, first as general counsel for the Oklahoma State Banking Department, then as general counsel for the Oklahoma Bankers Association, prior to her work with BankersOnline.

Mary Beth has presented training programs for virtually every major national financial industry association, as well as more than a dozen state bankers associations and a host of other organizations. She is a frequent presenter of webinars and seminars. In addition, Mary Beth has written more than a thousand banking-related articles and is BOL Guru #1.

Brian Crow is Executive Vice President at Thomas Compliance Associates, Inc. in Chicago, IL. Brian brings 20 years of prior banking experience to the consulting field. He was most recently Assistant Vice President and BSA Administrator for a suburban Chicago bank, where his responsibilities included preparing the bank's annual BSA risk assessment and audit documentation. Earlier as Operations Officer at the same bank, Brian monitored AML activity, aided in the implementation of the bank's AML software, and designed the bank's authentication blocking program that helped to reduce debit card fraud losses by 95 percent. Brian's responsibilities also included managing the bank's Regulation E claims, managing the bank's courtesy overdraft program, reviewing Reg CC hold notices for accuracy, and processing claims for fraudulent signatures and endorsements.

Mr. Crow has been, and continues to be, an education consultant for BOL Learning Connect, conducting webinars that have covered VISA/MasterCard chargebacks, debit card compliance and fraud prevention for hundreds of banks. It was in this role that Mr. Crow was recognized as a Bankers Online Guru in 2011.

Like many of us, Mr. Crow began his banking career as a teller, working his way up to head teller and then branch management responsibilities. He earned a B.A. degree in Theology from Concordia University, River Forest, Illinois. Because of his education background, Brian has been given the unofficial title of "Security Evangelist" as he strives to help financial institutions protect their bottom line from losses related to fraud. You can contract Brian at