Monitoring High-Risk Accounts
Question: We have some accounts that are consuming a lot of time with regards to monitoring and reporting suspicious activity. Could we charge, at our discretion, for accounts that we have deemed high risk under BSA a "monitoring fee"? Of course we would disclose it as necessary.
Answer: Federal regulations do not prohibit imposing such a fee. However, you should be careful to comply with Regulation DD in making disclosures. In addition, you should not do anything that indicates to the customer that their activity is considered suspicious and is being reported.
Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 10, 9/05
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