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Question & Answer
Question: We have a bank holding company, and non-bank subsidiaries- in this particular case, a finance company that handles automobile loans. I do BSA training, including the members of the bank holding company board. The member from the finance company called and said that in light of the information about SARs, he thought we had to report on an application the finance company had received. The down payment on the auto had been made with a counterfeit check. I agreed, and we're getting ready to file the SAR. My question-should I also be holding training sessions on BSA for the finance company employees?
Answer: "Absolutely," says FinCEN's Charles Klingman, who said you must have appropriate procedures in place which include training. Part of that requirement is in 12CFR225.4 and Reg H. The first reference, under 225.4 has to do with the Suspicious Activity Report. It says in part (f)… "A bank holding company or any nonbank subsidiary thereof, or a foreign bank that is subject to the BHC Act or any nonbank subsidiary of such foreign bank operating in the United States, shall file a suspicious activity report in accordance with the provisions of Sec. 208.20 of the Board's Regulation H, 12 CFR 208.20."
Copyright © 1998 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 8, No. 6 5/98
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