BSA Definitions Amended

As you probably recall, the Remittance Transfer Rule in Regulation E (Electronic Funds Transfer), went into effect on October 28, 2013.  The types of transactions covered under the rule were expanded, some of which, have been covered under the Bank Secrecy Act (BSA).  This overlap caused certain transactions to fall outside the BSA definitions of “funds transfer” [§ 1010.100(w)] and “transmittal of funds” [§1010.100(ddd)].

To avoid these transactions falling outside the grasp of the BSA, FinCEN recently issued a final rule to revise these definitions.  Specifically, the following verbiage was added to each definition:

Electronic fund transfers as defined in section 903(7) of the Electronic Fund Transfer Act [15 U.S.C. 1693a(7)], as well as any other funds transfers that are made through an automated clearinghouse, an automated teller machine, or a point-of-sale system, are excluded from this definition.

The final rule is effective January 3, 2014.

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Published
2013/12/06
Deb Irving
David Dickinson

David Dickinson

David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.

He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.

David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.

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