To change the first Plan, Anchorage have to have the OCC’s written approval
Plan
The brand new OCC’s payment specifications require one Anchorage’s Board out-of Directors (“Board”) yield to this new OCC to own comment and you can recognition an acceptable written plan discussing brand new remedial procedures needed to go and keep compliance with BSA/AML rules (“Plan”). The latest Board need certainly to fill in the action Plan inside a month away from the newest time of one’s Concur Buy. The action Package need, at least, identify (1) a description of one’s restorative tips had a need to reach conformity that have for each blog post of the Agree Purchase; (2) timelines having completion of the restorative strategies; and (3) anyone(s) guilty of completion of the corrective procedures. Pursuant on the Consent Order, Anchorage you should never significantly deviate of otherwise materially replace the Plan. Simple fact is that Board’s responsibility to ensure you to Anchorage government possess punctual observed all the corrective steps necessary for this new Concur Purchase. (more…)