How to industry sign banking georgia presentation safe
Welcome to this presentation
on the Bank Secrecy Act. We'll also cover important
aspects of anti-money laundering and the Office of Foreign
Assets Control requirements. Throughout this video, we'll refer to these areas
as BSA, AML, and OFAC. We'll focus on what you,
as a director, should know about these areas. We'll begin by providing
an overview of the BSA and the Financial Crimes
Enforcement Network's role in safeguarding
the financial system. We will discuss BSA
regulatory requirements for depository institutions, and touch on the FDIC's
examination process. Additionally, we'll
cover the elements of an effective OFAC sanctions
compliance program. The Bank Secrecy Act
is the common name for a series of
laws and regulations to combat money laundering
and terrorist financing. The BSA provides a foundation to
promote financial transparency and to deter and detect
those who attempt to misuse the US financial system
to launder funds or finance terrorist acts. The BSA has evolved
over the last 50 years, with several laws impacting
regulatory requirements. One of the most recent
pieces of legislation is the USA PATRIOT Act. These laws have resulted in
regulations that require banks to establish and maintain
BSA compliance programs. Provisions of the BSA cover traditional
depository institutions, such as banks,
savings associations, and credit unions. The BSA also applies to
non-bank financial institutions, such as securities
and commodities firms, loan or finance companies, money service businesses, insurance companies, casinos, and dealers in precious metals,
stones, and jewels. For purposes of
this presentation, we will focus on BSA
and AML requirements as they relate
to depository institutions. The Financial Crimes
Enforcement Network, referred to as FinCEN, is a bureau of the US Department
of the Treasury. FinCEN is designated
the administrator of the BSA. In this role, it has been
authorized to implement, administer, and enforce
compliance with the BSA and its associated regulations. FinCEN is also the US Financial
Intelligence Unit. In this role,
it collects data related to money laundering
and terrorist financing, analyzes it for
trends and patterns, and disseminates information
to law enforcement and other government agencies. FinCEN issues regulations
and guidance, communicates
with regulated industries, supports
examination functions, and pursues civil
enforcement actions. Importantly, FinCEN
has delegated much of its
examination authority to regulatory agencies,
including the FDIC. Now that we've covered
some BSA background, we'd like to focus on
BSA-related regulatory requirements
for banks. As a bank director, you are responsible for ensuring
that your bank has an effective, risk-based
BSA/AML compliance program. This is accomplished
by approving written policies and procedures,
providing sufficient resources and knowledgeable
BSA/AML personnel, and assessing ongoing
program compliance. The Board of Directors should
create a culture of compliance by setting
the tone at the top to ensure staff understands
the importance of and adheres to the bank's
BSA/AML policies, procedures, and processes. The BSA/AML compliance program
should be commensurate with the bank's
overall risk profile and based on a comprehensive
assessment of money laundering and terrorist financing risks. A bank's risk profile is
based on its products, services, customers, entities,
transactions, and geographic locations. In other words, as a bank's risk
profile increases or decreases, its BSA/AML compliance program
should be adjusted. So a comprehensive risk
assessment is the starting point for an appropriate
BSA/AML compliance program. A well-developed risk
assessment should factor in the types of products
and services offered, the customer base,
and the geographies served. The risk assessment
should include all branches and operational areas. The same risk management
principles that the bank uses in traditional
operational areas should be applied to assessing
and managing money laundering and terrorist financing risk. The bank's risk assessment
is not intended to be a static process. As a matter of sound practice, a bank should review
its risk assessment periodically and update it
to account for any changes in the bank's risk profile. For example, management should
update the risk assessment when new products
and services are offered or there is a change
in the bank's operations such as expansion through
merger or branching activities. The risk assessment
should be presented to the Board for approval since it is the foundation for
developing appropriate policies, procedures,
systems, and controls in relation to
the bank's risk profile. As a director, you are
responsible for ensuring that the bank
has an effective, risk-based BSA/AML
compliance program. So now, let's discuss the key
components that are required to be included in a BSA/AML
compliance program. The six components
that every bank's BSA/AML compliance program
must have are: A system of internal controls, independent testing of
the program's effectiveness, a designated individual
to manage the program, training for
appropriate personnel, an established Customer
Identification Program, and procedures
for customer due diligence. For the next few minutes, we'll discuss
each of these components. Let's start with
the internal control system. A system of internal controls
consists of policies, procedures, and processes
that management uses to manage, monitor,
and control money laundering and terrorist financing risks. Internal controls
should be designed to assist in ongoing compliance
with BSA/AML regulations. Policies and procedures
should address suspicious activity monitoring and FinCEN reporting
and recordkeeping requirements, which we'll discuss later. A BSA/AML compliance program
must be periodically assessed to determine
its effectiveness, which brings us to the
independent testing component. As a director, it's critical
that the Board ensure that an independent party
performs periodic testing. To meet that standard
of independence, management
can assign an employee who is not involved
in day-to-day BSA duties, hire an outside party
who does not already consult on the bank's
BSA/AML compliance program, or establish an arrangement
with another bank. In addition, that independent
party must be qualified. In other words, the person performing
the independent testing needs to have sufficient
BSA/AML knowledge for the complexity
of the bank's activities. The scope and frequency
of the independent testing should be commensurate
with the bank's risk profile. The testing performed should
assist the Board in determining whether the program
it has adopted is effective. In other words,
are there areas of weakness or areas in need of
stronger controls? As a director,
you need to ensure that the results
from the independent review are provided
directly to the Board or a designated Board committee, and that appropriate actions are
taken to address the findings. Now, we'll cover
the responsibilities for providing necessary
resources and personnel to coordinate and monitor
BSA/AML compliance. This is accomplished
by designating an individual to manage the program. Although the Board of Directors
is not responsible for day-to-day oversight, it retains ultimate
responsibility for BSA/AML compliance. Therefore, the Board must
designate a qualified individual responsible for coordinating and
monitoring BSA/AML compliance. The designated individual is commonly referred to
as the BSA Officer. This person must understand
BSA requirements, have sufficient authority to develop and enforce
board-approved policies, and have appropriate
staff and resources to effectively administer
the BSA/AML compliance program. Let's move on
to the training component. Training should include
regulatory and statutory requirements and cover the bank's
internal BSA/AML policies, procedures, and processes. Training must be provided
to all personnel whose duties require
knowledge of the BSA, and should be tailored
to the employee's specific job responsibilities. The BSA officer
should also receive training that is appropriate
for coordinating and monitoring
BSA/AML compliance, given the bank's activities
and risk profile. Further, as a director,
you should receive periodic training
to reinforce BSA concepts and stay informed
of developments in the BSA. All training
should be documented. It should be conducted
on an ongoing basis to reinforce compliance
responsibilities and cover changes to the BSA. Moving on,
we'll now take a moment to discuss the Customer
Identification Program or CIP. The purpose of a CIP
is to enable a bank to form a reasonable belief
of the true identity of the bank's customers. This will mitigate the risk that the institution
will be used as a conduit for money laundering
and terrorist financing. The customer identification
program must be written and include account
opening procedures and customer identification
and verification methods. The final component of a bank's
BSA/AML compliance program is implementation of
the Customer Due Diligence, or CDD, component. Banks have been performing
customer due diligence for many years. FinCEN issued regulations
requiring banks to perform ongoing CDD,
and to identify and verify beneficial owners
of a legal entity customer. First, let's talk
about ongoing CDD. The BSA/AML compliance program
must include appropriate
risk-based procedures for conducting ongoing CDD. Procedures must be designed
to understand the nature and purpose of
customer relationships to develop
customer risk profiles. Additionally, the procedures
must provide for ongoing monitoring to identify
and report suspicious activity and to maintain and update
customer information on a risk basis. CDD, in essence,
is understanding the nature and purpose of
customer relationships. This process starts
when a new customer first approaches the bank. Customers should provide details
on the proposed level and types of transactions. For example,
the bank should know if a business
is cash intensive or if a customer
plans to perform international wire transfers. Information gathered should
assist management in determining whether activities
and transactions make sense. Now, let's move onto beneficial
ownership requirements. Banks are required to establish written beneficial
ownership procedures. Under the beneficial
ownership rule, banks must identify and verify
the identity of a single individual
with significant responsibility to control, manage, or direct
a legal entity customer. Banks must also identify
and verify the identity of each individual, if any, who owns 25% or more
of that legal entity customer. Let's talk for a minute
about what we mean by legal entity customers. For purposes of
the beneficial ownership rule, a legal entity customer
is a corporation, limited liability company,
or other entity created by the filing of
a public document with the Secretary of State
or similar office, under domestic or foreign law. A bank may rely on
the identifying information for the beneficial owners as long as the person
opening the account certifies the accuracy
of the information. The bank must also have
no knowledge of facts that would reasonably
call into question the information's reliability. Beneficial ownership
requirements apply to new accounts
opened after May 11, 2018. Although the beneficial
ownership requirements do not apply retroactively, beneficial ownership
information may need to be updated for
existing legal entity customers based on the bank's
ongoing monitoring. We have just covered
the six components that must be present for you,
as a director, to meet your responsibilities for ensuring that the bank
has an effective, risk-based BSA/AML compliance program. The Bank Secrecy Act
also establishes other regulatory requirements
pertaining to suspicious activity
monitoring and reporting, currency transaction reporting,
and recordkeeping requirements. First, we will discuss
suspicious activity monitoring and reporting. Banks have a responsibility
to monitor, identify, and report suspicious
activities. If a bank becomes aware of an
unusual or suspicious activity or transaction, bank staff
must investigate further and determine whether
a Suspicious Activity Report, referred to as a SAR,
should be filed. A bank is not responsible
for finding evidence of or proving an underlying crime. Banks are required to file
a SAR when they detect known or suspected federal
criminal violations involving transactions: Indicating insider abuse
in any amount. Aggregating $5,000 or more when a suspect
can be identified. Aggregating $25,000 or more regardless of
a potential suspect. Aggregating $5,000 or more that may involve
potential money laundering or violations of the BSA, or that have no apparent
lawful purpose. Suspicious activity monitoring
and reporting processes are critical internal controls. As part of its
overall responsibility for ensuring
the bank has an effective, risk-based BSA/AML
compliance program, the Board should approve
policy guidelines that address
transaction monitoring, alert management, suspicious
activity investigations, SAR filing decisions, and ongoing
suspicious activities. FinCEN and the federal
banking agencies recognize that, as a practical matter, it is not possible
for a bank to detect and report all potentially
illicit transactions that flow through the bank. Accordingly,
examiners' focus will be on evaluating the bank's
policies, procedures, and processes
to identify, evaluate, and report suspicious activity. The Board should provide
adequate resources to ensure that suspicious activities
are appropriately identified, researched, and reported, taking into account
the bank's overall risk profile and the volume
of transactions. We want to spend a few minutes
talking more about effective monitoring
and reporting systems. There are five key components
to an effective system. The first component
is identification or alert of unusual activity. Alerts may come from a teller processing a suspected
structured transaction, law enforcement inquiries, or the review of internal
monitoring reports. Alerts can also be generated
from a transaction-based system. The second component
is managing alerts, which focus on processes used to investigate and evaluate
unusual activity. Management should establish
a defined process from the point of
the initial alert or detection to the disposition
of the investigation. The third component
is SAR decision making. After the bank researches and
analyzes the unusual activity, someone at the bank, either an individual
or a committee, makes a final decision
on whether to file a SAR. The decision maker
should have the authority to make the final
SAR filing decision. Banks should document
SAR decisions, including the specific reason
for filing or not filing a SAR. The fourth component
is SAR completion and filing. These are critical parts
of the SAR monitoring and reporting process. Procedures should be in place
to ensure SARs are filed in a timely manner,
are complete and accurate, and that the narrative provides
sufficient description of the activity reported,
as well as the basis for filing. The fifth and final component
is monitoring and SAR filing
on continuing activity. The bank should have
procedures that outline how it will monitor
future activity in the account and address
recurring SAR filings. The procedures should include
an escalation process for review of the identified accounts, including a recommendation if
such accounts and relationships should be maintained or closed. It's important to note
that all banks should have a monitoring system
addressing these components. The Board should make sure
that policies, procedures, and processes clearly describe
the steps that the bank takes to identify, monitor,
and report suspicious activity. But, to be clear,
the structure and formality of the components
will vary. We've just covered
the five elements of an effective suspicious
activity monitoring program. Let's talk more about
the Board's role in SAR filings. Established policies should
address Board notification of SAR filings. Management is not required to
provide actual copies of SARs to the Board; however, the Board
or a committee of the Board must be promptly
notified of SAR filings. It is critical that management
provide sufficient information on SAR filings to the Board,
so that Board members can fulfill fiduciary duties
to the bank, while being mindful of the
confidential nature of the SAR. Generally, the Board should
expect to receive information on SAR filings
to make informed decisions. This may include details
on the number of SARs and the type of
suspicious activities. The Board
should also have knowledge of potential illegal activities
in the bank's customer base. For example, if a SAR had been
filed on a large loan customer that was applying
for a new loan, the Board would likely
need this information to make an informed decision
on whether or not to extend additional credit. SARs are confidential
and cannot be shared outside the institution
or disclosed to the suspect. However, under guidance
issued by FinCEN, SARs may be shared with
the bank's parent entity. External requests for SARs,
including subpoenas, should be reported to the bank's
regulatory agency and FinCEN. Let's now spend a minute
talking about other BSA reporting and
recordkeeping requirements. In addition to SARs, banks
are also required to submit other reports to FinCEN, including Currency
Transaction Reports, also referred to as CTRs, and Designations of
Exempt Persons forms. Banks are
required to file CTRs for cash transactions
over $10,000. CTRs must be filed
electronically with FinCEN within 15 calendar days
of the transactions. Banks may exempt some customers
from the filing of CTRs under specific conditions
and circumstances. When a bank chooses to exempt
a customer from CTR filings, the institution must file
a form with FinCEN. Now that we've talked about
the bank's role in identifying and filing required reports
with FinCEN, let's talk about what FinCEN
does with this information. FinCEN receives
BSA reports daily from a wide range of bank and
non-bank financial institutions and analyzes the data
to identify individuals, entities,
criminal organizations, and techniques involved in
money laundering, terrorism financing, along with
other illicit activities. Information in the filings
can be used to connect seemingly unrelated
individuals and entities across the country
and around the world. SARs and CTRs are the primary
means for law enforcement to acquire information
on financial transactions. This reporting
has been instrumental in successful
criminal investigations. SARs filed by a bank can be combined with SARs
filed by other institutions to link complex
criminal activities. As a director,
remember that a SAR, no matter
how minor it may seem, may be part of a bigger puzzle
that is being put together by FinCEN
and law enforcement. We want to show you
how that works and how SAR filings
can play an important role in criminal investigations. We are going to
walk through an example based on an actual case, although the names and other
identifying facts in the case have been changed. Law enforcement
suspected that a company, which we will call
Bad Drug Company, was involved in
a drug trafficking operation. As part of
their investigation, they were tracking a suspect that was known to be
using multiple aliases. It took numerous SARs
that were filed by several banks for law enforcement
to put the puzzle together. Bank A filed a SAR
on EZ Convenience Mart for suspected structuring,
due to multiple cash deposits just under $10,000
made on the same day that appeared to be designed
to evade reporting requirements. Additionally, the deposits
did not appear to have a lawful business purpose
based on the bank's customer due diligence
or CDD of the business. Joe Charles
was also listed as a suspect and was the registered owner
of EZ Convenience Mart. Bank B filed a SAR
on EZ Convenience Mart for unexplained
multiple wire transfers to Charles Smith at Bank D. Chuck Joseph
was also listed as a suspect and was an authorized signer on
EZ Convenience Mart's account. Bank C filed a SAR
naming Jan Smith as a suspect for structuring,
due to multiple cash deposits just under $10,000, designed to evade
reporting requirements. Jan stated that the cash
was from winnings at the casino. Shortly after the cash was
deposited, Jan wired the funds to Charles Smith's account
at Bank D. Jan reported that Charles Smith
was her brother who lives out of state. Bank D filed a SAR naming
Charles Smith as a suspect for receiving multiple
large money orders and wire transfers from Bank A,
Bank B, and Bank C. Based on the bank's
CDD of Charles Smith, the deposits
and outgoing withdrawals had no apparent lawful purpose. Monthly, Charles Smith
wired a large amount of money to Joe Charles Smith's account
at Bank of Anytown. Bank of Anytown filed a SAR
naming Joe Charles Smith as a suspect for sending large
international wire transactions to Bad Drug Company's account
at Foreign Bank E. The source of funds
for the outgoing wires was monthly wires from
Charles Smith at Bank D. Based on the bank's CDD
of Joe Charles Smith, the incoming and outgoing wires
had no apparent lawful purpose. To summarize:
Five banks filed SARs. All five SARs
named different suspects. However, the names
were very similar and in four of the five SARs, the suspects
had the same date of birth and social security number. The SAR for Bank C
is not linked by date of birth or social security number, but there is activity tied to
an individual at Bank D. When Bank of Anytown
filed the SAR, law enforcement was able to tie
all the activity together and link the bad actors
to Bad Drug Company. Without the SAR filed by
Bank of Anytown, law enforcement
would not have had all the pieces to the puzzle. Law enforcement was able to
shut down Bad Drug Company. Suspicious transactions
at your bank may only be one piece
of a larger puzzle. Law enforcement agencies
use SARs to identify financial links
to illicit activity. These agencies supplement
ongoing investigations by analyzing FinCEN's database
for name matches to existing suspects
and their known associates. Law enforcement agencies
frequently use SARs to generate new leads and determine
whether to open new cases. We'd like to touch on
one final point relating to BSA reporting. Since CTR and SAR filings are
so useful to law enforcement, the BSA's recordkeeping
regulations require that banks maintain
financial records and provide information
to law enforcement upon request. Generally, all reports
filed under the BSA and the related
financial records must be maintained
for a period of five years, typically from
the date of the transaction or from
the date of account closure. Now, let's change gears and talk about
BSA examination procedures. During each safety
and soundness examination, the FDIC evaluates the bank's
compliance with the BSA and its implementing
regulations. Examiners assess
the appropriateness of the bank's program
in relation to its risk profile. They begin this process with
a review of the risk assessment and the bank's written policies,
procedures, and processes. The BSA examination
is focused on an evaluation of the BSA/AML
compliance program that we discussed earlier. The FDIC uses
a risk-based approach to assess BSA/AML compliance. Examination results
requiring bank follow-up may range from
minor technical issues to significant compliance
deficiencies. Examination findings
and recommendations will be discussed verbally throughout the entire
examination process and be included in the final
written Report of Examination. The written
Report of Examination is the principal
document of record by which examination
findings and conclusions are communicated to the bank. Let's spend a few minutes
discussing where BSA findings and recommendations
may be presented in the Report of Examination. Discussion of minor technical
issues may be limited to supporting Report of
Examination schedules, such as on the Violations
of Laws and Regulations page or the Risk Management
Assessment page. The FDIC will communicate
recommended corrective action for minor technical issues as supervisory recommendations
to the bank. These recommendations are
intended to inform the bank of the FDIC's views
about changes needed in the bank's BSA/AML
practices or operations. A principal purpose is to
communicate supervisory concerns so the bank can make
appropriate changes and thereby avoid more
formal remedies in the future. Discussion of significant
compliance deficiencies appears on several pages
of the Report of Examination. They are communicated
at the beginning of the Report of Examination on the Matters Requiring
Board Attention, or MRBA page. When bank management
promptly takes action to address concerns
detailed in MRBAs, potential problems
can be fixed early, before they become
more difficult to address. Significant
compliance deficiencies will also be discussed
in more detail on the Examination Conclusions
and Comments page. They will further be addressed on the Violations
of Laws and Regulations page. Significant
compliance deficiencies relate to a failure to provide an effective BSA/AML
compliance program-- meaning there are deficiencies in one or more of
the required program components. We would now like to provide
more detail about significant
apparent violations that relate to
program components. Significant apparent violations
relate to a pattern or practice of noncompliance
with the BSA and its implementing
regulations. To be clear, significant
apparent violations are not isolated
or technical issues. Violations of
the internal control component may be cited when systems
are lacking or ineffective or if the bank
has failed to follow its own internal
control procedures. An apparent violation for the
independent testing component could occur
when an independent review has not been completed within
a reasonable timeframe based on
the bank's risk profile, the reviewer is not
independent or qualified, or when the review itself
is ineffective. Violations of the BSA officer
component commonly result when the Board
has not appointed a BSA officer, the designated individual
lacks the necessary authority, or the BSA officer
does not have the expertise or resources
to adequately perform the job. An apparent violation of the
training component could occur when a bank doesn't maintain
sufficient training records, the training is inadequate, or the training
is not effective, resulting in significant
weaknesses in internal controls. Violations of the CDD component
may result when an institution has not adequately determined
a customer's risk profile, resulting in ineffective
suspicious activity monitoring. In addition to citing apparent
violations for deficiencies in individual
program components, the FDIC may also cite an overall BSA/AML compliance
program failure. When the FDIC does find
significant issues with BSA compliance,
enforcement actions can result. Let's briefly discuss this. Enforcement actions
can be informal, such as a Board Resolution
or Memorandum of Understanding, or formal, such as
a Cease and Desist or Consent Order. Directors need to understand
that BSA/AML compliance is a critical
risk management function. It is important
that the Board of Directors ensures prompt correction
of significant deficiencies related to a BSA/AML
program component. Existing statute
requires the FDIC and the other federal
banking agencies to take formal
enforcement action in response to a BSA/AML
compliance program failure. Additionally,
existing statute requires a formal enforcement action
be issued in response to repeat compliance program
deficiencies. Before we move on,
we want to emphasize that the vast majority
of FDIC-supervised institutions are successful
in complying with the BSA. We recognize the resources
that banks expend to comply with the BSA. And, to be clear, most banks have sound
BSA/AML compliance programs. Historically, less than
1% of the BSA examinations that the FDIC performs
in a year results in a formal
enforcement action. Lastly, we would like to
take a moment to discuss the Treasury Department's Office of Foreign Assets
Control, or OFAC, economic and trade-based
sanctions programs. OFAC administers and enforces
economic and trade sanctions based on US foreign policy
objectives. Although OFAC requirements
are separate and distinct from the BSA,
banks are also required to comply with
OFAC's sanctions programs, which share a common
national security goal. For this reason, many banks view
compliance with OFAC sanctions as related to BSA
compliance obligations. Similar to BSA compliance, it is important for
the Board of Directors to understand
the risks and controls necessary for OFAC compliance. OFAC sanctions programs
require that a bank either block accounts
and other property, or prohibit or reject
unlicensed trade and financial transactions. All US persons,
including US banks and their foreign branches,
bank holding companies, and non-bank subsidiaries must comply
with these sanctions. Many banks achieve this
by maintaining a written OFAC compliance program that is commensurate
with the bank's risk profile. Just as with the BSA/AML
compliance program, a risk assessment is a key link for developing an effective
OFAC compliance program. A risk-based OFAC compliance
program should provide for appropriate internal controls
for screening and reporting transactions
and account information, designate an employee
responsible for OFAC compliance, implement training programs
for appropriate personnel, and establish independent
testing for OFAC compliance. BSA/AML compliance programs
are integral elements in the prevention
and detection of bad actors seeking to misuse
the financial system. Banks should take reasonable
and prudent steps to combat money laundering
and terrorist financing and to minimize
their vulnerability to the risk associated with
such activities. The FDIC recognizes
the challenges and costs associated with
BSA/AML compliance. This is especially true
as criminal organizations and terrorist financiers
use creative and increasingly
sophisticated methods to misuse the financial system. The vast majority of
FDIC-supervised institutions are successful
in complying with the BSA, and play an important role
in promoting public confidence and stability
in the financial system. Directors cannot adequately
carry out their fiduciary duties without a general understanding
of BSA/AML and OFAC regulatory
requirements. To summarize,
the Board of Directors should understand the importance
of BSA/AML and OFAC, the consequences
of not complying, and the risks posed to the bank. As with other areas
of bank operations, the Board should request
and receive regular reports on the bank's compliance with BSA/AML
and OFAC requirements. There are many other sources
of information available to further supplement your
knowledge of BSA/AML and OFAC. For additional regulatory
information, please refer to: FDIC Rules and Regulations,
Section 326.8 Bank Secrecy Act Compliance. FDIC Rules and Regulations,
Part 353 Suspicious Activity Reports. Title 31 Chapter X: Financial Crimes
Enforcement Network. FFIEC Bank Secrecy Act
/Anti-Money Laundering Examination Manual. You may also refer to
the following websites for more information: www.fdic.gov www.fincen.gov www.treasury.gov/ofac. Additionally,
each FDIC Regional Office has a designated BSA specialist
that is available to answer BSA/AML and OFAC-related
questions. The bank's Case Manager can
provide you contact information. As we conclude,
we'd like to thank you for viewing this presentation,
and remind you that this video is part of the FDIC's Technical
Assistance Video Program. Other videos can be found at
www.fdic.gov/resourcecenter. If you have questions or
comments regarding this video, please email the FDIC at:
supervision@fdic.gov.
