EEO-1 Report Reminder: Sept. 30 Filing Deadline
Most banks with 50 or more employees are required under the Equal Employment Opportunity Act to file an EEO-1 Report due September 30, 2007. The data is used for a variety of purposes including enforcement, self-assessment by employers, and research. Each of the reports collects data about gender and race/ethnicity by some type of job grouping. This information is shared with other authorized federal agencies in order to avoid duplicate collection of data and reduce the burden placed on employers. Although the data is confidential, aggregated data is available to the public.
This year, federal regulators have made substantial changes to race, ethnicity and job categories which must be used on the report. The new data requirements will ask most banks to survey existing employees to update their ethnic classification. The Equal Employment Opportunity Commission has opened its Web site to accept 2007 EEO-1 reports, where banks can submit data between now and the Sept. 30 deadline. The online survey report can be found at www.eeoc.gov/employers/surveys.html
FinCEN Goal: Match BSA Exam Process to BSA Risk
Acording to a FinCEN “Bank Secrecy Act Effectiveness and Efficiency Fact Sheet” released late June, FinCEN’s goal is to match risk-based examination procedures to risk-based obligations. FinCEN and the regulatory community recognize that not all financial institutions are subject to the same risk. An institution with minimal to no international business that serves only a handful of communities does not share the same risk profile as a bank that does business around the world in many currencies.
Therefore FinCEN will initiate a joint effort with the federal banking regulators to ensure that financial institutions and regulators treat compliance obligations in a manner that helps to avoid expenditures that are not commensurate with actual risk. Over the coming months, in keeping with the evolution of the risk-based system, FinCEN and the regulators will work to translate this concept into more concrete practice, with a view to providing more direction in guidance and future revisions to the FFIEC Examination Manual.
FinCEN has been working with the IRS, state regulators and federal functional regulators to address many issues dealing with MSB oversight and MSB access to banking services. These efforts will result in the production of MSB examination materials using the success of the FFIEC Examination Manual as a model. FinCEN also has committed to crafting a more narrow definition of MSBs. Many of the estimated 150,000 to 200,000+ entities that are presently covered may only engage in financial services that pose little to no opportunity for money laundering. A risk-based reduction in covered entities would result in a better concentration of examination resources.
To review FinCEN’s “BSA Fact Sheet” in its entirety, go to www.fincen.gov/bsa_fact_sheet.pdf
OCC Report on Best Practices to Prevent Foreclosures
The Office of the Comptroller of the Currency (OCC) published “Foreclosure Prevention: Improving Contact with Borrowers,” an Insights report on best practices loan servicers are using to improve their contact rate with delinquent mortgage borrowers to help prevent foreclosures.
These best practices include, but are not limited to, the use of sophisticated scoring models, customer friendly approaches, partnerships with nonprofit credit counselors, and web-based information on workout options.
The OCC and the federal banking agencies are encouraging financial institutions to work with homeowners who are unable to make their mortgage payments. The agencies have stated that institutions will not face regulatory penalties if they pursue reasonable workout arrangements with borrowers.
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