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Lending to Legal Entity Customers

Wednesday, March 25th, 2020   10:00 am - 11:30 am CT

Length: 1 hr 30 min     Sponsored by Bank Webinars

Click Here to register $265.00

Click Here to register and receive CD recording $395.00

BSA examiners are digging deeper and asking more questions about lending to legal entity customers. Could a BSA examiner find loan fraud that was missed by your institution’s due diligence process? Does your institution have a system for identifying false statements and identity theft attempts on loan applications?

Do your lenders know these activities may require filing a suspicious activity report? Is your process for documenting beneficial ownership effective? This program will address the four core elements of the CDD (Customer Due Diligence) Rules.

Commercial lenders are also required to follow several core lending regulations. Key disclosure requirements will be included in this session. Which regulations apply to commercial loans? What if a loan is secured by real estate? Are there exceptions when real estate is taken as “an abundance of caution”? Can examiners assess civil money penalties for violations?

Program Highlights

  • What are five reasons to conduct BSA training for Commercial Lenders?
  • What are some of the BSA “red flags” and risk factors in commercial lending?
  • What types of due diligence questions should you ask legal entity loan applicants for BSA compliance?
  • Steps for BSA due diligence throughout the life of the loan.
  • Review of how to comply with the four core elements of the CDD (Customer Due Diligence) Rules that include:
    • Customer Identification and verification
    • Beneficial Ownership identification and verification of a “legal entity”
    • Understand the nature and purpose of customer relationships to develop a customer risk profile
    • Ongoing monitoring for suspicious transactions, and, on a risk basis, maintaining and updating customer information.
  • Overview of commercial loan compliance hot spots, including fair housing, Regulation B, Flood Disaster Protection Act, Fair Credit Reporting Act, accommodation loans, HMDA, and insider lending

Who Should Attend?

This informative session will provide a greater understanding of BSA requirements for commercial loan applications, including CDD requirements. It will benefit loan officers, loan assistants, loan operations staff, compliance officers, BSA staff, auditors, and trainers.


Susan Costonis is a compliance consultant and trainer. She specializes in compliance management along with deposit and lending regulatory training.

Susan has successfully managed compliance programs and exams for institutions that ranged from a community bank to large multi-state bank holding companies. She has been a compliance officer for institutions supervised by the OCC, FDIC, and Federal Reserve.

Susan has been a Certified Regulatory Compliance Manager since 1998, completed the ABA Graduate Compliance School, and graduated from the University of Akron and the Graduate Banking School of the University of Colorado. She regularly presents to financial institution audiences in several states and “translates” complex regulations into simple concepts by using humor and real life examples.