314(b) Filer
Question: We are having a heavy debate about whether to become a 314(b) filer. Can you give me some good reasons?
Answer: Sure. First, the government really would like you to participate because they feel that the information sharing process may help government investigations by enabling the industry to identify patterns sooner.
Second, the exchange of information with other institutions may help to protect your institution from losses. If you can determine earlier, with another bank's help, that a customer is laundering money, you can take action sooner.
Third, think about doing business after the entire FACT act takes effect and those identity theft flags start popping up. That can only raise the sensitivities of information about customers and you are likely to have situations that also involve money laundering or terrorism that you will want to be able to share with other institutions.
Finally, it provides you with a safe harbor when information covered by 314(b) is actually exchanged. In short, for the simple act of filling out and filing that form, you gain a great deal.
Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 7, 7/04
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