Newsletter - Archives - Wayne Barnett Software

Premium Products / Personal Service

The BSA Examiner - Archives

The BSA Examiner is a quarterly newsletter published by Wayne Barnett Software.

2025

Volume 99 – 4th quarter

Case #1 – FinCEN Alternative Collection Method to Obtain TIN

When a widow walks into a branch after her husband passed, a new Federal Reserve CIP clarification helped meet her with empathy at a critical time while also remaining compliant.

Case #2 – A Cautionary Bank Tale

Telltale signs of ACH fraud and kiting help banks stay one step ahead of money mules. New NACHA rules help strengthen this monitoring.

2025

Volume 98 – 3rd quarter

Case #1 – Fraud in the Rescue Squad

When a trusted treasurer in Alabama misused more than $45,000, it was strong bank monitoring and fast action that stopped the bleeding. Diligent teams used the Barnett Suspicious Activity Monitor tool to catch fraud and preserve taxpayer dollars.

Case #2 – Fuel Theft and Cartel Financing

FinCEN’s latest alert (FIN-2025-Alert002) shines a spotlight on fuel theft as a major funding source for cartels. With red flags ranging from mismatched wire activity to suspicious addresses, community banks need to stay sharp to detect and report these schemes.

Update – Fedwire ISO 20022 Migration

In July 2025 Fedwire, the US standard for wire transfers, officially moved to ISO 20022. While inbound wires from Fed ran smoothly, outbound transitions were more challenging. We give an update on how community banks managed the shift.

2025

Volume 97 – 1st quarter

Case #1 – What Jason Bateman Taught Me about Money Laundering

Netflix’s Ozark gave us more than suspense — it offered a fictional but surprisingly accurate look at money laundering schemes. From structuring to shell companies, Marty Byrde’s playbook highlights what happens when BSA/AML controls fall short. Here’s what community banks can learn.

Case #2 – Tell Me you Love Me When Glenda fell for a man she met online, she unknowingly became a money mule in a romance scam. As these scams grow more sophisticated, financial institutions must sharpen their monitoring and customer due diligence practices to spot them early.

2024

Volume 96 – 4th quarter

Case #1 – The waiting is the hardest part. M&A transactions at community banks are commonly held up by regulators’ concerns about BSA risk ratings. If your bank is hoping to sell in the next 3-5 years, get your BSA operations in order now.

Case #2 – Make that connection. The National Defense Authorization Act (NDAA) of 2020 strengthened FinCEN’s authority to impose and revise anti-money laundering (AML) rules. As we get further from the start of the 2020 pandemic, expect the rules to connect to more vigorous enforcement actions. Simple, consistent BSA reporting will go a long way.

2024

Volume 94 – 3rd quarter

Case #1 – Brilliance appreciated! Your bank’s card processors probably depend on a web security service. Will it catch more recent card number phishing attempts, such as this one?

Case #2 – Same outcome, different victims.

Thousand-cut fraud makes a comeback. This time, criminals use social media (Tik Tok) to scale a check fraud scheme. If you’re considering moving from manual processes to BSA software, you’ll have a leg up here

2024

Volume 93 – 2nd quarter

Case #1 – HAL 9000 to the rescue. Your bank probably enforces two-factor authentication for online access. But, has your bank implemented this consistently, with no convenient workarounds for hackers?

Case #2 – Finders keepers? Nope, finders weepers! Does your bank let customers charge their phones in the lobby, as a convenience? Do you sometimes see chargers left in the lobby? These are an attack vector for spyware, which can cause unauthorized withdrawals.

2024

Volume 92 – 1st quarter

Case #1 – A stinky phish. Does you bank prohibit employees from using their personal PCs when working from home? Most banks do, due to security concerns. But has your bank implemented this same rule for its directors? If so, are you sure they’re following it?

Case #2 – Too much to fix. Is your bank ready to fire a director that violates the SAR disclosure rules? Do your directors know this? Does your bank have a plan for litigation, in the event you have a director who talks too much?

2023

Volume 91 – 4th quarter

Case #1 – From horribly bad to just very bad. Nationwide, losses from check fraud are the highest in history. Regions bank reported that in the third quarter of 2023, their total losses from check fraud was $53 million. That’s an improvement from the second quarter loss, but still an estimated 5% of YTD income. We outline how our check fraud strategy works and ask you to consider if it’s time for new software.

Case #2 – From just very bad to horribly bad. Contracts entered into for more than market value are illegal, per FIRREA of 1989. Bankers not old enough to remember the go-go days of the late 80s and early 90s are learning the hard way that trusting what a software salesman says can come back to haunt you.

2023

Volume 90 – 3rd quarter

Case #1 – Neither gone nor forgotten. FinCEN will start gathering Beneficial Ownership Information (BOI) on January 2, 2024. Bankers must still obtain BOI for new accounts, and it’s likely they will have more BOI chores to do.

2023

Volume 89 – 2nd quarter

Case #1 – FedNow … but maybe not now. FedNow is the new payments system from the Federal Reserve. The promotional information from Fed give us hope that this will be a great system. But our contacts tell us this new system is 80% over budget and still considered “buggy” by Fed’s internal auditors. We don’t recommend early adoption.

Case #2 – Don’t let them take the money and run. Drawdown wires (aka debit wires) were all the rage 25 years ago. The rage stopped when lots of banks lost lots of money. Do you care to guess what’s all the rage again? We don’t recommend caution here; instead, we recommend total avoidance.

2023

Volume 88 – 1st quarter

Case #1 – An expensive haircut. Homeless people are being used by Organized Crime to commit check fraud. The Wall Street Journal, CNBC and AARP have also reported on this growing type of crime.

Case #2 – Maybe not illegal … but maybe so. In most states, it’s not illegal to cash a check made payable to a business. However, if the payee of the check is using the cash for illicit purposes, the bank could be charged with money laundering or as an accessory to a crime.

2022

Volume 87 – 4th quarter

Case #1 – You don’t have to … but heaven help you if you don’t. There is nothing in federal law that requires banks to do OFAC scans after each SDN update. But those that don’t are being harshly criticized by their regulators.

Case #2 – NSF refund update. There’s a lot of speculation and rumor about what’s going on … and I guess we’re adding to it. But we’re trying our best to offer interesting insights.

2022

Volume 86 – 3rd quarter

Case #1 – The cost of failure is high. For years, most institutions have been lackadaisical about OFAC updates, because the risk of banking an SDN was low. But now that the SDN list has grown to more than 30,000 names, the need for stringent update procedures is absolute.

Case #2 – Everyone does it this way … but we bet they won’t anymore. The federal courts system, in a series of actions brought by the Federal Trade Commission (FTC), has determined that NSF fees charged by many banks are an unfair or deceptive act or practice (UDAP). Banks throughout the country are scrambling to adjust their NSF procedures and determine who is entitled to a refund of fees.

2022

Volume 85 – 2nd quarter

Case #1 – Actually, numbers can lie. Check fraud is at an all-time high. City and county government agencies are the preferred targets for professional international thieves, and stopping the losses is more difficult than ever before.

Case #2 – The Church of the Sacred Tax Deduction. An old tax scheme is being marketed again, and bankers that aren’t looking for it may have an uncomfortable meeting with their regulator.

2022

Volume 84 – 1st quarter

Case #1 – Kids can be expensive. A common theme with embezzlers is that they are loved and trusted by executive management. That often means no one is reviewing their work–and that’s a big mistake.

Case #2 – It’s worth a second look. Most banks won’t recognize the full benefit of the rising interest rates. We tell you why in this story.

Case #3 – Penny wise, pound foolish. Trying to outsmart the regulators is a bad idea. And lately, it’s also a very expensive one.

2021

Volume 83 – 4th quarter

Case #1 – We don’t do that. Oh, wait a second …. Most banks don’t have procedures to search for mobile deposit fraud. Every bank should –and that’s especially true for banks that don’t offer mobile deposit.

Case #2 – The checklist. Altered checks and fraudulent checks are creating significant losses for community banks. You can’t stop this crime without software.

2021

Volume 82 – 3rd quarter

Case #1 – What’s old is new. The authorization rules for consumer ACH transactions changes on September 17, 2021. This could be bad news for your bank.

2021

Volume 81 – 2nd quarter

Case #1 – Rules and suggestions, you decide. The regulators can’t order a financial institution to buy a BSA system. But they can issue an MRA that can only be resolved with the purchase of a BSA system. We share two stories where this was the case.

2021

Volume 80 – 1st Quarter

Case #1 – Changes are coming, some will be good. Recent changes to federal law will mostly eliminate the beneficial ownership recordkeeping requirements for financial institutions. However, it’s a multi-step process that will take a few years to implement.

2020

Volume 79 – 4th Quarter

Case #1 – It was a moo-ving experience. If you bank originates commercial wires based on the presence of a signature, and you didn’t see the customer sign the request form, your bank is probably breaking the law..

Case #2 – We know it was you … probably. When it comes to commercial wires, the rules for “Proof of authorization” may be more onerous than your bank realizes.

2020

Volume 78 – 3rd Quarter

Case #1 – Fried chicken, cooked books. People that own multiple businesses sometimes find creative ways to lower their tax bill, and that’s not always a good thing.

Case #2 – Searching for unlocked potential. A lot of people are looking for a new career or a side-hustle. Sadly, a lot of con men know this and are ready to take advantage of those who are overly trusting.

2020

Volume 77 – 2nd Quarter

Case #1 – The crops aren’t the only thing dusty. A BSA officer has to know more than the law. They also must know when a business plan doesn’t sound realistic.

Case #2 – No “fun” in this family’s dysfunction. A family business strategy that doesn’t make sense should be watched closely. In many instances, transaction coincidence indicates criminal enterprise.

2020

Volume 76 – 1st Quarter

Case #1 – Did I do that? Learn about duplicate check presentment fraud with mobile deposits.

Case #2 – No foundation to build on. How a contractor obtained advances on a construction loan without authorization. No one was watching.

Case #3 – It has to add-up. Does your BSA software vendor provide data-validation tests

2019

Volume 75 – 4th Quarter

Case #1 – Not even the price is high. Is lending money for hemp production a good idea?

Case #2 – The list is growing like a weed. Serving the cannabis industry can be profitable, but creates extra expense and regulatory scrutiny.

Case #3 – Everything Changes. The newsletter is going green.

2019

Volume 74 – 3rd Quarter

Case #1 – Up in Smoke. The pros and cons of banking businesses that grow or sell marijuana.

2019

Volume 73 – 2nd Quarter

Case #1 – This isn’t a shaving nick. The fraud known as “death by a thousand cuts”.

2019

Volume 72 – 1st Quarter

Case #1 – Pink cowboy boots. An increasingly common ACH fraud that preys on the lonely.

Case #2 – We’ll give you a hug over the phone. Be sure you understand the terms of your auto-renewal obligations before you sign the contract.

2018

Volume 71 – 4th Quarter

Case #1 – The devil you know is better. How do you show the regulators you’re actively looking for significant unexplained changes (SUCs)?

Case #2 – What he said, what they heard. How do you classify high risk accounts? Hint: it’s not just looking at cash.

2018

Volume 70 – 3rd Quarter

Case #1 – We’ve seen it, we’ve heard it. What we are hearing about expectations for risk-based AML procedures.

2018

Volume 69 – 2nd Quarter

Case #1 – Things are getting better. Common questions on the new Customer Due Diligence Requirements (CDDR) and beneficial ownership rules.

2018

Volume 68 – 1st Quarter

Case #1 – It SUCs if you’re prepared. What exactly is a significant unexplained change (SUC) and how to you look for it?

2017

Volume 67 – 4th Quarter

Case #1 – It’s not getting any easier. Federal banking agencies described how their organization intends to implement the Beneficial Ownership rules.

Case #2 – These coins aren’t spare change. How do you monitor for bitcoin transactions?

Case #3 – Making his list, checking it once. Should you do FinCEN 314(a) checks on people whose only relationship with your bank is they’re a beneficial owner?

2017

Volume 66 – 3rd Quarter

Case #1 – The rule for 20 years. Are you required to scan your outgoing ACH transactions for OFAC compliance? Are you sure you want to?

Case #2 – Cheap can be expensive. Lack of compliance with BSA and AML rules can cost you more for remedial reviews.

Case #3 – You ask, we answer. We answer your common questions on the beneficial ownership rules.

Bonus downloads:

OFAC Guidance for ACH

FiNCEN Guidance for CTRs

2017

Volume 65 – 2nd Quarter

Case #1 – What’s their refund policy? Common misconceptions on the beneficial ownership rules and risk-based procedures.

2017

Volume 64 – 1st Quarter

Case #1 – Hiding in plain sight. Does your OFAC system check all the names?

Case #2 – Wishful thinking. banks that aren’t increasing their BSA budgets are making a mistake.

Case #3 – That was no gentleman. Do you have a legal obligation to notify your agency when you see someone in authority acting irresponsibly?

2016

Volume 63 – 4th Quarter

Case #1 – Don’t bet on it. What is your bank is doing to search for unlawful internet gambling (UIG)?

Case #2 – A rough cruise. A the cashier received commission payments for endorsing software.

Case #3 – A new normal. Looking at industry-peer analysis.

2016

Volume 62 – 3rd Quarter

Case #1 – No question about it. An introduction to beneficial ownership, customer relationships and activity monitoring under the Enhanced Due Diligence rules.

2016

Volume 61 – 2nd Quarter

Case #1 – Insult to injury. How you could be on the hook for ACH transactions that happened months ago.

Case #2 – Cheap and very good. Criminal services to fraudulently alter a check are inexpensive and easy to obtain, and increasingly causing mobile deposit fraud.

2016

Volume 60 – 1st Quarter

Case #1 – Editors note. Is your cloud-based virtual server is yours alone? Also, how organized crime uses ISOs (private ATMs) to launder money.

Case #2 – A growing trend. The burden of stopping account takeovers rests mostly with your bank. Unfortunately, in most cases, bill-pay transactions aren’t available for review until late in the day.

2015

Volume 59 – 4th Quarter

Case #1 – That cloud is a thunderhead. The cloud isn’t near as safe as the they want you to believe.

Case #2 – More knowledge equals less losses. Finding from a recent white paper on managing losses from DDA charge-offs.

Case #3 – ISO is becoming the new MSB. What you may be required to do if your bank sponsors Independent Sales Organizations (ISOs)–and even if you don’t.

2015

Volume 58 – 3rd Quarter

Case #1 – Long distance robbery. Banks are increasingly becoming a victim of DDOS attacks. How you can prepare, and what to do if you are.

2015

Volume 57 – 2nd Quarter

Case #1 – They said what? How your bank may be liable for fraudulent government benefit payments.

Case #2 – Yes ma’am, it’s the law. A lot of examiners believe they have a right to see anything retained by a bank. What does the law say?

Case #3 – Mr. EDD. You have a better chance of finding a “talking horse”, than finding two examiners that agree on what constitutes enhanced due diligence (EDD).

2015

Volume 56 – 1st Quarter

Case #1 – This fish hooks you. How a man in the middle malware attack, like SuperFish, works, and the risks it poses for your bank.

2014

Volume 55 – 4th Quarter

Case #1 – Bigger losses, smaller victims. Recent findings from ACH fraud studies showed smaller banks are increasingly targeted.

Case #2 – He seemed like such a nice young man. Wire fraud involving foreign college students. Be careful allowing wire transfers based on a phone call.

2014

Volume 54 – 3rd Quarter

Case #1 – Starbucks, anyone. Regulator are strongly encouraging banks to have a BSA system because of missed CTRs. Here’s why.

2014

Volume 53 – 2nd Quarter

Case #1 – A defining moment. How recent rulings affect the need for rigorous security controls of your internet banking system.

Case #2 – Sometimes, sorry isn’t enough. A corporate account takeover could cost you a loss from the fraud–and worse, the loss of a customer.

2014

Volume 52 – 1st Quarter

Case #1 – A little here, a little there … dang, it quickly adds-up. Read how organized crime used small-dollar counterfeit checks to steal hundreds of thousands of dollars.

Case #2 – And then, a little bit more. Fraudulent deposits can also be a source of check fraud.

Case #3 – Half just isn’t enough. Independent verification reports show most banks still ignore small cash transactions.

2013

Volume 51 – 4th Quarter

Case #1 – Back with a vengeance.

2013

Volume 50 – 3rd Quarter

Case #1 – Odd dog, new trick.

2013

Volume 49 – 2nd Quarter

Case #1 – Her momma done raised her right.

Case #2 – You know … I thought they looked familiar.

2013

Volume 48 – 1st Quarter

Case #1 – Ok, maybe not so dumb … but don’t bet on it.

Case #2 – CAT tales.

2012

Volume 47 – 4th Quarter

Case #1 – This CAT ain’t cool.

2012

Volume 46 – 3rd Quarter

Case #1 – Dumb and Dumber.

2012

Volume 45 – 2nd Quarter

Case #1 – New Sheriff, new rules.

Case #2 – A little here, a little there.

Case #3 – Ratings made easy (or at least easier).

2012

Volume 44 – 1st Quarter

Case #1 – The future is now.

2011

Volume 43 – 4th Quarter

Case #1 – Not large but painful none the less.

Case #2 – The first loss is the smallest loss.

2011

Volume 42 – 3rd Quarter

Case #1 – Well chosen targets.

Case #2 – It’s what you don’t see that’s most scary.

Case #3 – You’ll never break even.

2011

Volume 41 – 2nd Quarter

Case #1 – Old law, new interpretation.

2011

Volume 40 – 1st Quarter

Case #1 – Tats, piercings and wingtips.

Case #2 – It’s not our fault … no, really, it’s not. (Want to bet?).

2010

Volume 39 – 4th Quarter

This edition of The BSA Examiner focuses on the risks inherent in ACH operations.

2010

Volume 38 – 3rd Quarter

Case #1 – Protection is key … better make that keys.

Case #2 – Revolting in more ways than one.

Case #3 – A fool and his money.

2010

Volume 37 – 2nd Quarter

Case #1 – Clearly visible, cleverly hidden.

Case #2 – Dang Internet.

2010

Volume 36 – 1st Quarter

Case #1 – The bullet they dodged may ricochet back.

2009

Volume 35 – 4th Quarter

Case #1 – Be careful what you DON’T spend.

Case #2 – High risk, low reward.

Case #3 – High risk, low reward #2.

2009

Volume 34 – 3rd Quarter

Case #1 – International ACH Transactions (IATs) are here.

Case #2 – Wild cards.

2009

Volume 33 – 2nd Quarter

Case #1 – Be careful what THEY ask for.

Case #2 – Wanted: dead or alive.

Case #3 – A very happy ending.

2009

Volume 32 – 1st Quarter

Case #1 – The signs are there.

Case #2 – The E doesn’t stand for Easy.

Case #3 – Easier exemptions.

2008

Volume 31 – 4th Quarter

Case #1 –A necessary delay.

Case #2 – It’s all in the numbers.

2008

Volume 30 – 3rd Quarter

Case #1 – Hiding in plain sight

Case #2 – It could be your mother, or mine.

Case #3 – You’re in good company.

2008

Volume 29 – 2nd Quarter

Case #1 – More work and more expense—that’s a FACT.

2008

Volume 28 – 1st Quarter

Case #1 – No one said it would be easy.

Case #2 – A closer look is wise … and required.

Case #3 – No good deed goes unpunished.

2007

Volume 27 – 4th Quarter

Case #1 – Broken slot machine – Part II.

Case #2 – No question about it.

Case #3 – One bank’s trash, another bank’s treasure.

2007

Volume 26 – 3rd Quarter

Case #1 – Paying-out like a broken slot machine.

Case #2 – To close for comfort.

2007

Volume 25 – 2nd Quarter

Case #1 – Do as we say, not as we do.

Case #2 – Don’t blame others for your relationship troubles.

Case #3 – They have to have it, and you have to make sure.

2007

Volume 24 – 1st Quarter

Case #1 – A new measuring stick.

Case #2 – Judgment day.

Case #3 – It ain’t what you think, but it’s suppose to be.

2006

Volume 23 – 4th Quarter

Case #1 – Hidden in plain sight.

Case #2 – So advanced, it’s simple.

Case #3 – Use our list, check it twice.

2006

Volume 22 – 3rd Quarter

Case #1 – More reporting required.

Case #2 – These questions warrant statements.

Case #3 – Easier than you think.

2006

Volume 21 – 2nd Quarter

Case #1 – It’s all in the numbers.

Case #2 – The same, only different.

Case #3 – Now you see it, now you don’t.

2006

Volume 20 – 1st Quarter

Case #1 – Traveling light.

Case #2 – One size does not fit all.

Case #3 – No agreement here.

2005

Volume 19 – 4th Quarter

Case #1 – Good underwriting is no excuse

Case #2 – They aren’t yours, but treat them like they are.

Case #3 – A New Year, a new headache.

2005

Volume 18 – Summer

Case #1 – That’s not a rose you smell.

Case #2 – Seeing what you don’t see.

Case #3 – You don’t have too, unless you say so.

2005

Volume 17 – Spring

Case #1 – Auditing the auditor.

Case #2 – Sign on the dotted line…and they’re not saying please.

Case #3 – The best solutions are simple.

2005

Volume 16 – 1st Quarter

Case #1 – Give them credit, they’re inventive.

Case #2 – MSBs, a few more things to consider.

Case #3 – The light at the end of the tunnel…..is a fast approaching train.

2004

Volume 15 – Fall

Case #1 – We don’t feel your pain, and we hope we never do.

Case #2 – Howdy Sheriff.

Case #3 – Ask for help and make sure you get it.

2004

Volume 14 – Summer

Case #1 – If you think it’s hot now, wait until winter.

Case #2 – Don’t force the issue.

Case #3 – Exception to every rule.

2004

Volume 13 – Spring

Case #1 – Patience expired.

Case #2 – A different shade of blue.

Case #3 – The law hasn’t changed, but expectations have.

2004

Volume 12 – 1st Quarter

Case #1 – Guilty until proven innocent.

Case #2 – Wiring problems.

Case #3 – Spread em’ out.

2003

Volume 11 – Fall

Case #1 – Hanging from the Branches.

Case #2 – We rate with the best.

Case #3 – It’s hard to argue with the numbers.

2003

Volume 10 – Summer

Case #1 – Their hands are tied; don’t let yours get cuffed.

Case #2 – Show us the money.

Case #3 – No partial credit.

2003

Volume 09 – Spring

Case #1 – We sent her to training, so it must be her fault.

Case #2 – You better know it when you see it, and, you better look for it.

Case #3 – You can have him, we don’t want him.

2003

Volume 08 – 1st Quarter

Case #1 – The magic number is eight.

Case #2 – It was good last year. But this year it isn’t enough.

Case #3 – Size does matter.

2002

Volume 07 – Fall

Case #1 – The proof is in the numbers.

Case #2 – It doesn’t say “Annual” for a reason.

Case #3 – Believe it, they’re not joking.

2002

Volume 06 – Summer

Case #1 – Oops, our mistake.

Case #2 – The job’s all yours.

Case #3 – This kite don’t fly.

2002

Volume 05 – Spring

Case #1 – It’s not where you finish, it’s where you start.

Case #2 – Quit your batchin’.

Case #3 – Copy that card.

2002

Volume 04 – 1st Quarter

Case #1 – It’s not just a suggestion, it’s the law.

Case #2 – What they don’t know can hurt you.

2001

Volume 03 – Fall

Case #1 – They’re making the list; you check it twice.

Case #2 – Eight is enough.

Case #3 – It’s all in the numbers.

2001

Volume 02 – Summer

Case #1 – $10 million? Ouch, that had to hurt.

Case #2 – So close, but so far away.

2001

Volume 01 – Spring

Case #1 – Sometime, the usual is unusual. And yes, it is your business.

Case #2 – More money than you need.

Volume 77 – 2nd Quarter

Case #1 – The crops aren’t the only thing dusty. A BSA officer has to know more than the law. They also must know when a business plan sounds feasible..

Case #2 – No “fun” in this family’s dysfunction. A family business strategy that doesn’t make sense should be watched closely. In many instances, transaction coincidence indicates criminal enterprise..

Volume 76 – 1st Quarter

Case #1 – Did I do that? Learn about duplicate check presentment fraud with mobile deposits.

Case #2 – No foundation to build on. How a contractor obtained advances on a construction loan without authorization. No one was watching.

Case #3 – It has to add-up. Does your BSA software vendor provide data-validation tests

Volume 77 – 2nd Quarter

Case #1 – The crops aren’t the only thing dusty. A BSA officer has to know more than the law. They also must know when a business plan sounds feasible..

Case #2 – No “fun” in this family’s dysfunction. A family business strategy that doesn’t make sense should be watched closely. In many instances, transaction coincidence indicates criminal enterprise..

Volume 76 – 1st Quarter

Case #1 – Did I do that? Learn about duplicate check presentment fraud with mobile deposits.

Case #2 – No foundation to build on. How a contractor obtained advances on a construction loan without authorization. No one was watching.

Case #3 – It has to add-up. Does your BSA software vendor provide data-validation tests