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#1216714 - 07/13/09 08:39 PM NBFI Question
DebL Offline
Gold Star
Joined: Jan 2007
Posts: 314
CA
We recently came across an account for a customer who appears to be some sort of financing company. According to the exam manual, this would be considered an NBFI.

While we have a solid program in place for our MSBs, I'm a little lost on what to do with this one.

Does anyone have any suggestions on how to complete EDD on this sort of company?
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Of all the things I've lost, I miss my mind the most.

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#1216718 - 07/13/09 08:44 PM Re: NBFI Question DebL
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
With mine, I monitor their deposits in and checks out - twice a year.
I take a sampling of each and document that they are consistent with the stated business.
NBFIs can be finance companies, investment companies, jewelers etc.
If they are a local well known entity that should be more than enough EDD.

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#1216722 - 07/13/09 08:48 PM Re: NBFI Question MagicCity
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
My AML software from Bankers Toolbox allows me to search for a customer by any part of their name.
As a result I was able to find several NBFIs by entering keywords such as Investment, Fund, Finance etc.

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#1216727 - 07/13/09 08:51 PM Re: NBFI Question MagicCity
DebL Offline
Gold Star
Joined: Jan 2007
Posts: 314
CA
Thanks for the info!

Do you know if there are any special licensing requirements for lending companies that aren't banks?

Maybe it's my wishful thinking but it seems like they should be registered or something.
_________________________
Of all the things I've lost, I miss my mind the most.

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#1216760 - 07/13/09 09:36 PM Re: NBFI Question DebL
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
It depends on what exactly they do...
Check with your state website.
In Florida it is called Department of Business and Professional Regulation where you can check on the licenses of Doctors, Realtors, Investment Brokers etc.

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