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April 22
A Banker's Guide to Virtual Currency
Andrew Beal

April 24
BSA/AML Compliance: Writing the SAR Narrative
Ken Golliher

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HSA Basics
Whitney Johnson

April 29
Required Training for Loan Originators
Mary Beth Guard and Jack Holzknecht

May 13
Overdraft Practices in Today's Regulatory Environment
John Burnett

May 14
Reg E Claims - Allocating Liability Correctly
Andy Zavoina



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#1531326 - 04/04/11 05:02 PM Privately Owned ATM's
Nail Offline
New Poster

Registered: 02/25/11
Posts: 4
Does any one have a worksheet/risk assessment they use for cusotmers who have privately Owned ATM machines?

Thanks.

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BSA/AML/CIP/OFAC
#1531942 - 04/06/11 09:40 AM Re: Privately Owned ATM's [Re: Nail]
ComplianceGurl Offline
Gold Star

Registered: 07/23/07
Posts: 389
I do. PM me your email address and I will send you what I use.

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#1532499 - 04/06/11 04:21 PM Re: Privately Owned ATM's [Re: ComplianceGurl]
Ann C Offline
New Poster

Registered: 05/28/10
Posts: 8
Loc: Washington state
Would you be willing to share what you use? We have just gone through our BSA exam with the OCC and their hot button this time was NGOs. I was surprised it wasn't privately owned ATMs.

Thanks,
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AnnC
ncnb

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#1532519 - 04/06/11 04:36 PM Re: Privately Owned ATM's [Re: Ann C]
Purex Offline
100 Club

Registered: 10/04/05
Posts: 171
Loc: North/Central Louisiana
Would you be willing to share with me also. I have just been put in charge of organizing something on all of our Privately Owned ATMs?
Thanks
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#1532690 - 04/07/11 09:48 AM Re: Privately Owned ATM's [Re: Purex]
Branch ops Offline
Junior Member

Registered: 07/29/05
Posts: 44
Loc: Massachusetts
Ann C - what was the suggestion for the NGO's due diligence?

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#1532932 - 04/07/11 03:16 PM Re: Privately Owned ATM's [Re: Branch ops]
Ann C Offline
New Poster

Registered: 05/28/10
Posts: 8
Loc: Washington state
The OCC was pretty specific on doing due diligence and enhanced due diligence on all new NGOs. We also had to go back and review our exisitng NGOs to make sure none were high risk. We've added a line to our Risk-rating profile for new accounts and made up a NGO profile form for any high risk NGOs using the bullet points from the FFIEC Manual. (page 320-321 in the Red Book.)
_________________________
AnnC
ncnb

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#1636977 - 12/08/11 12:24 PM Re: Privately Owned ATM's [Re: Ann C]
djalen Offline
New Poster

Registered: 12/02/11
Posts: 15
Loc: NJ
would anyone be willing to send me their worksheet or risk martrix for privately owned atm's? our auditors have been asking and we dont have any procedure in place yet.
Thank you

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#1644198 - 12/29/11 11:24 AM Re: Privately Owned ATM's [Re: Nail]
b.b Offline
New Poster

Registered: 12/29/11
Posts: 24
Would someone mind sending me their worksheet or risk matrix as well?

Thanks,

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#1644345 - 12/29/11 02:20 PM Re: Privately Owned ATM's [Re: Nail]
Banker Chick Offline
Junior Member

Registered: 07/07/06
Posts: 35
Loc: TN
Just a word of caution...

Some states prohibit the private ownership of ATMs. Be sure to check your state's statute.
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Opinions expressed are my own and do not necessarily reflect those of my employer.

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