Cenlar FSB uses its best efforts to comply with the requirements of the Bank Secrecy Act (BSA), as amended by the USA Patriot Act, all other related laws and the related regulations of the Department of Treasury, Office of Foreign Assets Control(OFAC) and FinCEN. Cenlar FSB has a comprehensive BSA Program and a BSA Department consisting of a BSA Officer, two (2) BSA Analysts and a BSA Administrator.
As part of the BSA Program, Cenlar performs the following activities:
Monthly OFAC Scans of all client’s borrowers and coborrowers on the Servicing System;
314(a) FINCEN Scans against all client’s borrowers and coborrowers on the Servicing System;
Investigations of potential suspicious activity on loans referred to the BSA Department by the line of business;
Investigations of potential suspicious activity on loans identified in our Transaction Monitoring Reports.
From time to time, an investigation warrants the BSA Department to reach out to the client regarding a question we may have or a request for additional information. In addition, potential OFAC or 314(a) matches and investigations resulting in suspicious activity warrant a communication to the client. In the cases of a potential OFAC or 314(a) match, we may need additional information from the client to rule out a positive match or simply make the client aware of the nature and details of a suspicious activity found in an investigation. Today, these questions and requests go through the assigned Client Relationship Managers at Cenlar and our clients.
In order to streamline communication, prevent sensitive communication from being passed through parties that may not have a direct interest and, most importantly, ensure we have a direct audit trail of all communication, we would like to have all of our requests, questions and communications be directed from the BSA Department at Cenlar to the BSA/Compliance Officer/Contact at your institution. We feel this will expedite the investigation process and enable an open, direct communication between parties that would have a common interest in BSA related items. In addition, we hope this will also allow our client’s to have a direct contact to the BSA/Compliance Department at Cenlar for any questions or issues that you may have.
Please provide the following contact information for your BSA/Compliance Officer/Contact at your earliest convenience:
Direct Phone Number:
Below you will find the contact information for Cenlar’s BSA Department: