Blair Rugh
Chief Compliance Advisor
Blair is one of the preeminent experts on the United States banking laws and regulations, with more than 40 years of experience in commercial and investment banking.
He has authored compliance manuals recognized by the banking industry as the definitive treatise on banking law and regulations. His contributions to thought leadership in the industry include extensive experience as a speaker to bankers’ associations, and written numerous articles published in banking journals.
Blair’s background includes a Bachelor Science degree in chemical engineering from the University of Kansas as well as a Juris Doctor degree from Southern Methodist University.
Blair now serves as the Chief Compliance Consultant Advisor to the TriComply Services division of Temenos.
Latest articles from Blair Rugh
Stop Payment or Revocation of Authorization
Blair Rugh, Chief Compliance Advisor, explains how the processes have changed from stopping physical paper check payments vs. the electronic payments most make today.
Consumer Compliance Supervision Bulletin
The Federal Reserve has begun issuing a new publication titled, “Consumer Compliance Supervision Bulletin”. Its purpose is to alert banks and bankers about compliance violations that its examiners are seeing…
The Courts Always Have the Final Word
There were three interesting federal court decisions recently that give guidance beyond the court's holding.
Who Should Be Your Compliance Officer?
On several occasions I have had a community bank president tell me that for some reason the bank's compliance officer was leaving and ask my opinion about who should be hired to fill the position.
Suggestions on How to Write a Procedure
In recent weeks we have expressed the importance of policies and procedures and given some advice on how to write a policy.
Vacation Time: Is it Mandatory?
It’s summer time, the kids are out of school and many families take their vacations.
The Bank Bribery Act
Sometimes, it seems like Congress and the regulators take all of the fun out of everything. A gift from a customer every now and then is just one of the…
Bank Secrecy Act: Suspicious Activity Reporting
I have been doing some work recently on suspicious activity reporting under the Bank Secrecy Act (“BSA”) and for me that always raises the issue of what is meant by “suspicious".
The Penalty If You Don’t Balance the Books
Make sure that there is nothing in your institution that a rogue examiner can sink his or her teeth into to avoid paying penalties.
CFPB Reports
The Consumer Financial Protection Bureau publishes a lot of reports. Most of them are not too interesting, but a few do have some interesting information. Recently, the CFPB published its…
A Time To Rethink Discrimination Policies
Stay abreast of the law and make sure that your policies and procedures are up to date as changes occur.
We Has Met the Enemy and They Is Us
Many of the regulations on the banking industry are the result of egregious things that financial institutions have done to their customers.
Bankers and the Fair Debt Collection Practices Act
Very few financial institutions fall within the FDCPA’s definition of debt collector, but almost all financial institutions have debts that they must collect from time to time.
Bankers and the Fair Debt Collection Practices Act
If an institution is collecting delinquent loans that it owns or services for third parties, it does not fall within the definition of debt collector and the provisions of the…
Dear Santa, What I Really Want for Christmas
What I really want for Christmas is a new government agency, the Bankers Financial Protection Bureau.
Regulation E: Stop Payment Versus Revocation of Authority
Customer service at a financial institution must understand the distinction between a stop payment of an electronic item and a revocation of authorization.