Financial Institution Services

For our financial institution clients, Flynn+Sweeney provides the following services:

Bank Secrecy Act and Anti-Money Laundering

Risk Assessments - We provide a process-by-process evaluation of inherent risks associated with products, services, customers, entities, transactions and geographic locations unique to your Bank. An assessment of controls in place to mitigate and monitor those risks, and what the likelihood and impact of an occurrence may be.

Independent Testing - We perform the independent testing based on the FFIEC’s BSA/AML Examination Manual.

Staff Augmentation - We help financial institutions by providing staff as needed to help respond to weaknesses identified during an examination or other BSA testing. Examples of staffing previously provided is the review and dispositioning of alerts generated from an automated system and aiding management with staff deficiencies to train staff on BSA requirements and complete required reviews (e.g. annual exemption requirements).

National Automated Clearing House Association (Nacha)

Risk Assessments - We provide a process-by-process evaluation of inherent risks associated with those processes, an assessment of controls in place to mitigate and monitor those risks, and what the likelihood and impact of an occurrence may be.

Annual Audit - We perform the annual audit as required by the Nacha Operating Rules and Guidelines.

Tools Development - We help financial institutions with tools that may be needed for proper oversight of their ACH program. An example of an area where we have helped with the development of tools is an ACH Originator calculator to identify higher risk ACH Originators and those that may require additional due diligence (e.g. WEB or TEL Originators).

Regulatory Compliance

Risk Assessment - We provide a process-by-process evaluation of inherent risks associated with specific regulations, an assessment of controls in place to mitigate and monitor those risks, and what the likelihood and impact of an occurrence may be.

Compliance Audits - We perform testing for financial institutions of the lending and deposit compliance. With each consultant having over 20 years of regulatory compliance experience, not only do we perform the testing to identify violation of law, but we continually look for areas where improvements can be made to an institution’s program to enhance their Compliance Management System.

Staff Augmentation - We help financial institutions by providing support for the Bank’s Compliance Management System (CMS). We help financial institution’s CMS and board management oversight by aiding in the establishment and support of the Compliance Program, including reviewing or helping write compliance related policies and procedures, performing compliance related training and building out monitoring programs for compliance areas. We also help institutions respond to examination violations by helping with the remediation process. An example includes performing a review of loans that have an identified systemic violation where reimbursement may be required, recalculating the Annual Percentage Rate (APR) for restitution.