CDD questions and the squirm factor

Posted By: John Burnett

CDD questions and the squirm factor - 07/22/14 06:21 PM

I'm trying to get a good feel for the types of questions under the heading of "Due Diligence" that your frontline people (tellers, new accounts, other) are having trouble asking new customers (personal and/or business), either because they are uncomfortable asking the questions or because they are getting firm pushback. Due diligence under BSA/AML or other due diligence is fair game. Do they have trouble with certain types of questions when opening personal accounts but not business accounts, or vice versa. Any problems with CDD or EDD questions related to resident alien/nonresident alien status? Other problems getting CDD answers? Any sense of whether the problem is customer pushback or simple employee reluctance to ask?
Posted By: edAudit

Re: CDD questions and the squirm factor - 07/22/14 07:54 PM

On the business realm; From my observation a great deal of it falls in not knowing how to as the question. If given the chance most legitimate business customers you can not keep quite about their business if asked correctly.
Posted By: ACBbank

Re: CDD questions and the squirm factor - 07/22/14 08:48 PM

Agree with Ed. Obtaining information on business customers is usually not an issue with the exception of obtaining information on beneficial owners.

Personal customers are a different animal. A lot of people are unwilling or simply afraid that the "bank will report them to the government." Ironically enough after a BM or someone higher up the food chain explains why, we usually get the info. Occasionally we refuse or close the account.

I don't think its training related either. Tellers and some CSRs just don't have the necessary people skills to handle an irate or upset customer.
Posted By: PeeWee

Re: CDD questions and the squirm factor - 07/22/14 09:03 PM

I agree with Ed and ACB.

Citizenship is a requirement in our core system so our employees don't seem to have a problem with that. On businesses, years ago, I got lots of calls and emails as we were implementing a CDD program but those calls and emails have all but stopped...I attribute alot to training and a thorough QA check.

As an added note, many of our commercial accounts are opened with Treasury Management involvement. TM really gets it - they have a very good understanding of their customers and therefore I glean reliable information obtained through the due diligence process.

If I had to take a guess, I'd say the problem normally lies in the employees' reluctance to ask.
Posted By: Sunshine Lady

Re: CDD questions and the squirm factor - 07/22/14 09:22 PM

I would agree with it is more the employees' reluctance to ask because we give them training and tools. Having been in a customer facing position for over 30 years, I encountered all types of people. Some would just tell you what you needed and others you had to pry it out of them. Our frontline people are trained to ask, but are afraid of what kind of answers and reactions they will get even though it has been stressed that the bank needs to know who we are doing business with. We have some front line personnel that can get anything out of customers and some who either cannot or will not.
Posted By: P*Q

Re: CDD questions and the squirm factor - 07/23/14 01:38 PM

We get a ton of resistance when branch folks ask people their occupation, we like that info to feed into our automated ATM system for risk rating purposes but we find at least half refuse to provide it. But don't think twice about giving us all of their other personal info. Makes no sense to me.
Posted By: edAudit

Re: CDD questions and the squirm factor - 07/23/14 02:02 PM

I can only imagine what the occupations are when customers do not wish to talk about it.
Posted By: TryingtoComply

Re: CDD questions and the squirm factor - 07/23/14 05:03 PM

Hmmmm.... That's pretty interesting. I don't believe we have had issues obtaining occupations. A review of deposits might at least indicate who they are working for if they are depositing payroll checks.
Posted By: ACBbank

Re: CDD questions and the squirm factor - 07/23/14 05:29 PM

^ Agreed. We would not permit someone to open an account here unless theyh disclosed their occupation and employer.
Posted By: BSA Smitten

Re: CDD questions and the squirm factor - 07/24/14 02:28 PM

occupation is part of CDD and the regulators wrote us up when they found a few accounts without it... years ago