Our bank has a separate policy and procedures for UIGEA. Are any of you putting anything about UIGEA in any of your other bank policies such as (Wire Transfer Policy, ACH Policy, BSA/AML Policy or OFAC Policy)?

We have chosen not to reference our UIGEA Policy in any other bank policies.

Whether it's the "red flags" or Regulation GG, you greatly elevate the importance of a topic when you incorporate it into your BSA/AML policies.

You can tweak your due diligence and enhanced due diligence questions in such a way as to elicit the information you need without mentioning Regulation GG in any way.

We've added it to our Credit & Card Debit Card Program policies, mostly to document how we're blocking those transactions. We've also added it to our Merchant Bankcard Acquiring Program policy.

We have added it to our signature cards.

Thanks for the replies.

Is it required to be added to account opening disclosures like the signature card or deposit account rules, etc.?? I can't find anywhere that it states it 'has' to be. Just wondering if our disclosure need to be updated or if a handout at account opening is sufficient. thanks

We use Wolter's Kluwer signature cards and those terms and conditions have been updated to include the language. why have another piece of paper to hand out? Nothing says they have to be included in the sig card, just that it must be provided to everyone opening a new account after 12-1-09.

For business accounts or for all? Just curious!

WK provided us with a seperate disclosure statement that needs to be signed at account opening for business customers. They did not indicate to us that it had been added to the signature card documents?? Hmmm.

CSi has included veribage in both the business account master agreement, as well as the account agreement.

They added it to the terms and conditions for everyone!

Are you talking about the Form MPSC-LAZ? What section did they put it in?