Friday, September 30, 2011

Outsourcing and internal control in Banking Part.II



In this context, the establishment of collective audit providers could help save time and productivity for each establishment.
This optimization of the audit activities outsourced more and more interested in the Inspection Branch of the big banks. And working groups were formed in a pooled between several banks in order to define the terms of planning, implementation and monitoring of audits of providers. The working group is considering the establishment of a governance structure, a plan of joint audit and risk mapping for the shared use of audits should be part of common control risks of each institution without failing to respect the privacy principles of each Bank.

However, to date, nothing has yet been clearly defined and different approaches are envisaged for the implementation of shared audits:

* Audits carried out by joint team delegations
* Audits shared between delegations (each delegating the responsibility of an audit)
* Audits by authorized third parties

what could be the conclusions of this working group?
The operational implementation of a system audit activities outsourced based on audits shared between the delegating or on a joint team delegations, would seem the most logical and easiest to implement. But that solution presents risks to lead to potential conflicts of interest on the conduct of audits, the findings and the implementation of action plans. Thus, differences between schools could undermine the legitimate operation of the audits. The conduct of audits by authorized third parties, outside each bank, would then appear as the preferred solution as long as you specify the responsibility of each institution's contractual terms.
But should we in this case provide auditing services of third parties mandated?
Indeed, in the case of annual monitoring of outsourced activities, external auditors could be considered as service providers intellectual Internal Control. The control activity is necessarily "essential" it therefore falls within the scope of activities to be audited!

Under these conditions, the task of the Working Group seems difficult to reach consensus on a pragmatic and operative in order not to deport the weight of outsourced activities on control functions.

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Outsourcing and internal control in Banking Part.I


The use of outsourcing is a growing phenomenon that is a strategic choice for enterprises, generally guided by the objective of streamlining production costs and improve profitability. Did not escape this trend, banks are also appeal to external structures in order to give them in exchange for remuneration of non-strategic or unprofitable. For example, check processing is an activity often outsourced by the banks because it creates a significant load input and low added value.

But beware; the outsourcing of an activity does not prevent its control.
Indeed, 2007 orders involve clarifying the controls to be installed on the outsourced activities "essential." These changes are intended to ensure the principle of "no transfer of responsibility" of the Bank's external service provider. In this context, banks should review their internal control systems with a view to measuring, monitoring and control of risks related to outsourced activities. The controls must include details of:

* A guarantee of quality for normal service.
* The establishment of a plan for continuity of service by the service (commitment of recovery time).
* The protection of confidential information.

De facto, the outsourcing should result in a written contract between the provider and establishing external client. The contract shall contain a clause giving the right to regular audits and a statement of the steps taken by the continuous monitoring and periodic monitoring of outsourced activities. In view of these regulations, what are the good practices observed in the square as part of outsourced providers to common? Given the fairly concentrated market providers, banks often resort to common providers. For example include BRINKS Evolution for transporting money or Experiance to check processing draining a very large market share on their respective activities.

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Banks will have to regain trust


The current financial crisis through the financial markets due to subprime write-downs but also with the announcement of an unprecedented fraud at Society General structurally alter the banking landscape and challenges acquired banks to the market, investors as well as their clients: the confidence of financial institutions.

Through the efforts of transparency, better management of their operational costs and optimizing their capital, banks have to adapt to a financial cycle that will require them to demonstrate their ability to innovate both in terms of respect new regulatory ratios in terms of cost reduction and business development. The impact of this crisis of confidence and the levers available to financial institutions to restore calm and confidence in the system should be done at the earliest.

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Thursday, September 29, 2011

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Monday, September 26, 2011

China investors shunning banks



You could fear that may happen in Europe, but in China it is happening. According to the official press, the four largest commercial banks are Chinese investors look to other alternatives - such as individuals and private companies - to deposit their money, it pushed by high inflation and low interest rates.

According to the Zhongguo Zhengjuan Bao (Journal of China securities), deposits of the Industrial and Commercial Bank of China (ICBC), China Construction Bank (CCB), Bank of China and Agricultural Bank of China (ABC) fell by 420 billion Yuan (48.6 billion Euros) during the first 15 days of September.

The business daily also argues that much of the funds were placed on a parallel credit market. If individuals and companies are certainly not having status to bank, they nevertheless offer pay about ten times higher than bank deposits. Recall that the rise in consumer prices was 6.2% in August, while the deposit rates at one year is only 3.5%. In the end, so investors lose purchasing power by placing their money in the bank.

It should be noted also that in early September, the rating agency Fitch said it may lower the sovereign rating of China in the next two years. Reasons: the heavy debt the Chinese banking sector, the latter having provided massive loans in recent months.

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Friday, September 23, 2011

Fitch confirms the highest score to Germany



The rating agency Fitch on Tuesday reaffirmed the "AAA" rating to Germany, and now it is the best position. The outlook remains stable on the other hand. A good report that offers the very interesting German debt investment safe haven status in these troubled times.

Speaking in a statement, Fitch highlights the following: a German economy "robust and diversified", "health" of the labor market, a macroeconomic management "prudent" investments and "vigorous". According to the agency, the prevailing market rate for the German debt if need be shown the safe haven status associated with it. However, that "the resolution of the crisis in the euro zone remains a determining factor for the stability of the German economy" notes Fitch.

"With a 40% share of German exports, 2% of GDP spent on existing support plans, and exposure of its banking sector to peripheral economies in the euro area, the risk of contagion from the crisis in Germany public debt remains high, "said Fitch, as well.

A position that echoes that of the IMF, the IMF saw as a likely scenario now possible spread of the debt crisis of the euro area financial system. "The banks' exposure to the fragile economies of the euro area is a fraction of the total, but is concentrated on a small number of institutions," said the agency also. The Landesbanken, regional public banks also remain a weak point of the German economy, Fitch believes that "an additional restructuring and consolidation is needed in this sector."

Recall that the Basel Committee refuses to recognize the present German peculiarity consists in that a large part of bank capital is composed of public hybrid capital which banks must pay interest to shareholders. Local authorities could be forced to run vast operations re-capitalization, the amount could be just "confessed" politically speaking.

For many years, observers indicate persistently that only two or three Landesbanken sufficient in Germany, instead of the seven schools being independent. But, of course, local politicians are hesitant to say the least to give up some of the prestige and economic power associated with these regional facilities.

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Thursday, September 22, 2011

New measures to support the American economy


The U.S. Federal Reserve, Central Bank of the United States (EDF) announced Wednesday that it would take further measures to support the U.S. economy, saying the resumption of the latter remained "slow". Among the measures: the sale by the end of June 2012 the equivalent of $ 400 billion in Treasury bills.


Subsequently, the Fed plans to buy an equivalent amount with a longer maturity in an attempt to lower interest rates and long-term power purchase real estate securities without increasing the size of its portfolio, the objective to support the mortgage market. The Fed also said it would keep its key interest rate near zero until mid-2013 if necessary.

On Tuesday, investors had taken for granted that the U.S. Federal Reserve (Fed) announced shortly measures to resume, background likely to increase demand for raw materials. While opening the meeting of the Monetary Policy Committee of the Fed, investors are already betting on a new "Operation Twist", which is to lower interest rates in the long term to boost the activity without act on interest rates in the short term.

In fact, such an operation is to extend the maturity of securities held in the balance sheet, ten years and over, to reduce rates, evidence to boost business investment and household on the housing market. Such a measure Devit also have an immediate impact on prices by devaluing the dollar and increasing demand in emerging markets.

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Tuesday, September 20, 2011

Sharp rise in bad loans of banks in Spain



Decidedly, things keep getting worse in Spain, while the Madrid Stock Exchange barely see the green, data published Monday by the Bank of Spain indicate that bad debts are Spanish banks amounted to 3.1 billion euros in July, reaching a total of 124.7 billion euros. Note also that the ratio of NPLs to total loans granted by the Spanish financial sector amounted to 6.94% in July, corresponding to a level not seen since February 1995. Induced by such a situation of rising unemployment and increasing household debt.

Recall in this connection that the mortgage-up over 70% of household debt. However, this often forgotten by the media to tell you is that almost 85% of Spanish mortgages in 2001 consisted of floating rate loans. Note that in other countries such as France and Germany, less than 20% of loans to the same period are of this type. A context that makes the Spanish market particularly sensitive to changes in interest rates from the European Central Bank ....

Let us recall that in Spain, the Euribor ((interbank lending rate in the euro area) in one year is the index most used to index the interest rate. Finally, 93.2% of families in debt for real estate purchases on the other side of the Pyrenees are at variable rates.

Tuesday, September 13, 2011

The price of gold a victim of profit-taking



Once is not custom, gold has not benefited Monday from its role as a safe haven. Investors seem to have the contrary "relieved" of their investment in the precious metal to cover losses in other markets. By mid afternoon, the price of an ounce of gold was trading around 1820 dollars, while prices went up Friday to 1885.90 dollars.

On Tuesday, gold had even reached a record high of 1921.15 dollars. A surge that has allowed some to reap serious benefits and allowing them to absorb the consequences of their unfortunate investments.
Let us recall that an ounce of gold was still up 15% in a month. The surge in gold is also hampered the last few hours by the renewed strength of the dollar, the greenback Monday reaching its highest level in six months against the Euro. A situation that makes it less attractive raw material purchases denominated in U.S. currency.

Still, the phenomenon could be a passenger, uncertainties regarding the euro area accentuated a little more each day. It should be noted as well as the largest gold funds listed globally, SPDR Gold Trust, saw the level of its holdings increase by 10.5 tons during the single day of Friday to reach 1,241 tons now.

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Saturday, September 10, 2011

Oil prices on the increase



Oil-barrel prices rose sharply Wednesday in New York, boosted by the weather and a report from the Fed to say the least optimistic about U.S. growth. The recovery of strength in the stock markets will do the rest. On the New York Mercantile Exchange, a barrel of light sweet crude for October delivery had soared to well over 3.32 dollars Tuesday, up to now the value of 89.34 dollars. Meanwhile in London, the price of Brent North Sea for the same period was trading at 115.80 dollars on the Intercontinental Exchange, rising 2.91 dollars so.

The price of crude rose sharply at the opening as markets react strongly to climatic conditions observed in the Gulf of Mexico, a region where most of the platforms provide a quarter of the oil consumed in the country. Investors have largely responded to the report published by the Office of Management and regulation of ocean energy resources (http://www.cmegroup.com/company/nymex.htmlBOEMRE), the latter indicating that, indeed, if Tropical Storm Lee, who reached Sunday Louisiana had inflicted no major damage, the fact remained that 37% of oil extraction and 18% of gas extraction in the area remained suspended Wednesday.

Although significantly a lower percentages of the values observed the previous day but at a level totally unexpected. Note also a possible disruption of production in Mexico, second largest exporter of crude to the United States while the National Hurricane Center reports that a tropical cyclone could pass within 48 hours, with a probability of 70%.

The price per barrel will also be benefited with the surge in global stock markets observed Wednesday, London and Paris rising more than 3%, while Frankfurt soared more than 4%. Another positive: the report of conditions contained in the Beige Book Federal Reserve (Fed), economic activity in the United States continued to grow at a moderate pace. An ad that has the merit of ending the cycle of bad news experienced in recent times.

Fitch could degrade China because of the banking sector



While the European Union and the United States is buffeted by a debt crisis without precedent, Thursday, rating agency Fitch said it may lower the sovereign rating of China in the next two years. Reasons: the heavy debt the Chinese banking sector, the latter having provided massive loans in recent months.

In an interview with Reuters, Andrew Colquhoun, head of Asia Pacific ratings at Fitch, has considered possible a downgrade in China from 12 to 24 months. "We anticipate a material deterioration in the quality of bank assets. If the problems of the sector are changing as we anticipate, or even worse, the next 12 to 24 months, this would lead us to lower the note," he warned.

Last April, already, Fitch lowered its rating outlook on China's "stable" to "negative", citing concerns that date on the financial stability of the country following the decision in Beijing to increase bank credit to maintain China's economic growth. Currently, Fitch assigns the note to China 'AA-', corresponding to the fourth highest level of its scale, position equivalent to that of Italy and a notch below that of Spain.

In early July, the rating agency Moody's had indicated that for its public debt to China stood at 36% of its Gross Domestic Product (GDP), taking into account the share of the debts of local governments for which Beijing assume direct responsibility. A few days earlier, the National Audit Office had indicated that the debts of the provinces, municipalities and districts Chinese rose late 2010 to 27% of Chinese GDP, representing a total of 1.163 trillion Euros.

The same office had, however, insisted that 63% of this debt would be repaid through revenue budget.

Now where the rub is; that they have borrowed huge amounts from the global financial crisis, via means of ad hoc structures called "platforms financing" or PFL.
Objective: To finance infrastructure and housing projects not always profitable.

But according to the National Audit Office; the "ability to pay is low and faces potential risks in certain areas and certain industries." Indeed, in a snowball effect, some local governments had to make new loans ... to repay the debts already contracted, also heavily dependent on land sales to meet their deadlines.

According to the auditors of governments of China, 108.3 billion yuan (11.8 billion) of loans were made or used fraudulently, the money ends up in banks or stock markets real estate.

Indeed, point out that as a guarantee, the PFL received capital that comes from land assets transferred by the community investment fund and ... fraud, bank lending in the short term what notionally provide a PFL time he gets a larger credit. All of which leads ultimately to the National Audit Office that the platforms of local funding must be "cleaned and regulated."

A bit worried, Moody's said that Chinese banks have lent billions of 8500 yuan (905 billion) out of 10'700 billion yuan (1.163 trillion euros) to local governments ... a situation that causes a high risk exposure.

"The debts existed before the global financial crisis, but they quickly accumulated in the last two years while investment by local governments has been used as a key tool" to boost the economy, adds Moody's.

Friday, September 9, 2011

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Monday, September 5, 2011

Fall in sugar prices in the International Market



sugar prices fell during the week just past, a decline that followed the publication of the International Sugar Organization (ISO) suggesting unfavorable prospects for a rise in prices. Already begun earlier this week, falling prices has gained momentum Friday after the publication of ISO.

The numbers speak for themselves: during the period from October 2011 to September 2012, surplus production is forecast at 4.2 million tonnes (mt). Recall that in March, the International Sugar Organization estimated that the campaign still going from October 2010 to September 2011, excess world production of sugar should be limited to 196,000 tonnes, against 1.2 million tonnes (Mt) previously expected.

It is true that Australia, the world's third largest exporter, saw its crop affected by heavy rains followed by floods, Cyclone Yasi destroying up to 10% of national production again affecting the country by more. Now, analysts believe that the next harvest from India, Thailand and Russia are expected to quickly compensate for the low volume of Brazilian production.

Investors also expect a revival production of sugar beets in the European Union. Also note that the stronger dollar has made sugar unattractive for exporters. In the end, knew the Liffe in London, a tonne of white sugar for October delivery was worth £ 752.30 early Friday afternoon against 780.60 Friday books about the same time. On the NYBOT-ICE U.S. per pound of raw sugar for October delivery was trading at 28.95 cents against 29.70 cents the previous week.

Ultimatum to Switzerland


The United States issued an ultimatum to Switzerland to track down tax evaders.
It heats between Switzerland and the United States! It is true that in times of famine ... It is important to scrape the bottom of the barrel and all the drawer bottoms.... even those safes Helvetia....

U.S. authorities do not kid with the fraudsters: they called and Switzerland to provide them Tuesday night at the latest data bank US citizens who have concealed their assets in the Confederation. This is indeed what the newspaper SonntagsZeitung reported Sunday, based on a three-page letter from the Deputy U.S. Secretary of Justice, James Cole, dated August 31 and addressed to the Helvetic authorities.

According to this, the United States have asked for details of their nationals involved in fraud, by requiring data Tuesday from the second bank from Credit Suisse. Those directly targeted: private clients and foundations that have filed at least U.S. $ 50,000 in federal government (approximately 35,000 Euros) over a period from 2002 to July 2010. Apart from Credit Suisse, a dozen other banks would Helvetic "stakeholder" in the case, including Julius Baer, Wegelin, the Cantonal Bank of Zurich and Basel cantonal bank.

According to sources familiar with the matter, banks Helvetic could be forced to pay a fine of approximately 2 billion Swiss francs to settle this new case of tax evasion.

Copper prices on rise!!!



The price of copper rose on Wednesday at 9304 dollars a tonne, its highest level since early August.Prices remain supported by strong concerns over the production of Chile. The country's largest exporter worldwide, is greatly affected recently by strikes in the mining sector.

Analysts at MF Global, official figures this week reported a fall of 18% of Chile's copper supply in July.A context that would fuel tensions in the market, while new social movements may emerge in the giant Grasberg mine in Indonesia, which represents 4% of world production of copper.

Finally, early Friday afternoon, a tonne of copper for delivery in three months traded at the LME 9025 dollars, 9006 dollars per tonne against the previous Friday.

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Sunday, September 4, 2011

Oil prices weighed down by Employment in US


The price of oil fell sharply Friday in New York, weighed down by strong employment figures sobering.
Stopping a part of the oil production in the Gulf of Mexico will not even possible to change that. A barrel of light sweet crude for October delivery has thus concluded the day at 86.45 dollars on the New York Mercantile Exchange (Nymex), down 2.48 dollars compared to the previous day. The course was even on the verge of reaching the threshold of 85 dollars, then limit its losses by closing.

You will note in passing that the current price fluctuations are far to affect the price of gasoline. Meanwhile in London, the Intercontinental Exchange, a barrel of Brent North Sea crude for October delivery closed at 112.33 dollars, dropping 1.96 dollars.

The courses were largely impacted by the monthly report on employment. However, while a positive balance of recruitment had been found for ten consecutive months and in contrast to analysts' projections, the American economy has not created any jobs in August. However, some analysts had estimated in early trading as climatic conditions in the Gulf of Mexico could reverse the trend, Tropical Storm Lee threatened oil installations producing a quarter of U.S. crude.

However, while almost 48% of oil production in the area was arrested, corresponding to 666,321 barrels per day, and 33% of offshore gas extraction, prices could rise. Another disturbing fact: according to forecasts from Barclays Capital, gasoline consumption in the United States fell by 4.1% in annual slippery during the summer period, however, conducive to the mobility of Americans.

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Scentsy was started with a simple idea—a safe, wickless best substitute to scented candles. But quickly grew into one of the most triumphant direct selling companies. Their wickless concept was born when two stay-at-home moms started selling decorative warmers designed to melt scented wax with the heat of a light bulb instead of a conventional wick and flame. Scentsy’s wickless candles are safe to use and they are smokeless, flameless and soot free one. With wickless candle bars and electric warmers we can enjoy the same sensory delights of traditional scented candles without the risk of any open fire. They offer wickless candles with more than 80 special delightful fragrances. Scentsy unwrapped its Fall/Winter 2011 Catalog with new present. Every page is loaded with great novel gift ideas like scentsy solid perfumes, scentsy premium warmers Sasha charitable cause Scentsy buddy. If you are a home maker with lot of friends and leisure time they you can make your idle time into treasure trove with lot of fun by hosting scentsy party by bringing your friends and Scentsy products together. You can join in their team with a little as of $99. You will get a free website, free online workstation and free credit card processing. All these support and pack up will help you to run ease of your business. They what else do you want? Join their team and reap the benefits.

Saturday, September 3, 2011

Fight Against Money Laundering -3



The directive strengthens the other hand the obligation to share information. The Financial Security Act of 2001 introduced the need for coordination among banking groups the fight against money laundering. This involves organizing the different entities of the group exchange of information necessary for monitoring the customer on a consolidated basis. With the third directive, banks will now have the opportunity to share information between groups and banking networks, institutions and even between non-group members, since they are subject to equivalent obligations.

Beyond measures of intra and intergroup, banks must comply with in 2008 a major European regulations, European harmonization of retail payments (SEPA - Single European Payment Area [6]). "Europeanization" of cash flows increases the need for more secure against the practices of money laundering or terrorist financing. In addition to a larger volume, banks will soon face severe regulatory constraints on compliance, security and traceability of financial flows.

The banks have already set up systems for monitoring and tracking capabilities including data collection (to detect and select unusual or suspicious transactions), but also reporting and archiving of tests conducted. Examination of the flow from the source of transactions, to verify the source of funds, is based on two main areas:

* Filtering: detecting the presence or absence in the black lists published by national and supranational regulation;
* And behavioral analysis: analysis of accounts and transactions in connection with the risk profiles to detect unusual transactions and suspicious behavior.

However, with the increasing internationalization of flows and extensive monitoring obligations to the beneficial owner of the transaction, major efforts are still needed to harmonize procedures for risk prevention (warning indicators adapted from the Know Your Customer rules, ... ) internationally. According to a KPMG study [7], although the expenses of banks in combating money laundering and terrorist financing have increased on average by 58% over the past three years, only 24% of international banks have at the moment of an effective system for monitoring transactions and accounts of the same customer across different countries ...

In conclusion, the successful implementation of the Directive is closely linked to be the ability of banks to develop a coordinated approach and a risk, for realism and efficiency.

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Fight Against Money Laundering -2



The scope of due diligence, previously limited to the financial sector now includes notaries, lawyers, accountants, auditors, tax advisers, estate agents, casinos, service companies and trusts, and insurance intermediaries . Monitoring the client is also extended to (s) recipient (s) number (s) [5] of the transaction: this additional requirement of identification, which seems difficult to implement, more complex work of banks.


The duty of care is now adjusted according to the risk that the client is. Each institution will define the level and nature of audit to be implemented towards the customer (identification and verification of identity on the basis of documentary evidence, gathering information on the purpose and nature of the relationship of business, followed by the business relationship ...) depending on the nature of its clientele, operation and services. The approach could also requires banks to be able to justify the adjustment of the audit.


To avoid duplication of identification procedures, the third directive sets up the principle of mutual recognition and acceptance of measurement results to identify clients: it allows the presentation of clients whose identification measures were carried out by banks and financial institutions located in the European Union. The ultimate responsibility then rests on the establishment to which the customer is introduced, that is to say the one who resorts to colleagues.


Banks have gradually established since the 1990s services fight against money laundering. They now emphasize the need for a group.

The first challenge for financial institutions is to continuously develop the culture of anti-money laundering with the group, and the training of employees by raising awareness (transmission of procedures and corresponding obligations, formation of the entire profession with warning indicators, lead to detect suspected cases ...). FBF offers on this since 2003, with the participation of Tracfin, a training evolution available to the entire profession, and consists of an awareness module and several modules specialized on specific issues.

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Friday, September 2, 2011

Fight Against Money Laundering



The international community has placed first among its priorities the fight against money laundering and the financing of terrorism. The 3rd Money Laundering Directive, published October 26, 2005 in the Journal. Official European Union must be transposed into national law by 15 December 2007. Repealing the previous guidelines, it represents an opportunity to clarify the text, and seeks to strengthen international cooperation and to transpose the new forty FATF recommendations.

The third directive has several developments in four major areas: the scope, due diligence and reporting, and enforcement. A considerable broadening of the scope of the declaration of suspicion ...
The scope of the crackdown, which covered the laundering of proceeds of crime, is now extended to offenses classified as "serious" fraud (especially taxes), corruption, and especially the financing of terrorism offenses and exposing them to a sentence of imprisonment exceeding one year. These last two points are particularly sensitive:

* One hand, terrorist financing differs from money in two aspects: it is usually based on a darkening own money, and it is not the source is at issue, but the destination of the funds (often low);
* On the other hand, if the French legislation does not change, the new definition of the offense would expand the scope of all economic and financial crimes, which would lead to increase reports of suspicious and blocking and Tracking.

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Goldman Sachs implicated in the scandal of foreclosures



The U.S. Federal Reserve (FED), Central Bank of the United States said Thursday it planned http://www.blogger.com/img/blank.gifto impose a fine on the U.S. bank Goldman Sachs for "malpractice" of its subsidiary, Litton Loan Servicing. The scandal of foreclosures has not finished talking to him ...

Even if Goldman Sachs has sold Monday the company involved in a huge scandal, however, the Fed has insisted that the bank "will be responsible for payment" of any fine inflicted by the Fed. In April, US regulators have reminded fourteen U.S. financial groups involved in the scandal, including Bank of America, Citibank, JPMorgan Chase, PNC and Wells Fargo, and a subsidiary of the insurer MetLife and British bank HSBC. But include Goldman Sachs at that time. But now, the Fed believes that Litton has made him as guilty of "negligence", "malpractice" and other "misconduct".

The scandal erupted late foreclosures in September 2010, driven by the controversy over the signatures so-called "robo signing" (acceptance almost to the chain of files without any real data verification) situation that led Bank of America, JP Morgan Chase and Ally Financial to suspend their proceedings.

Recall that the number of foreclosures implemented by banks in the United States reached a new record in August 2010. Financial institutions seeking so to "catch up" accumulated in the processing of cases in mortgage trouble. Banks seized 95 364 units during this period, exceeding 2% the previous record set in May The number of entry procedures performed had increased by 3% over one month and 25% in annual slippery.

In an attempt to redress the balance, the Fed imposed Thursday at Goldman Sachs to conduct an independent audit of all procedures that were being seized in Litton in 2009 or 2010 to determine the amount of financial damage caused to the borrowers.

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