I wanted to see what everyone is looking for when they do their MSB site visits? We're trying to get a form together for our account officers to use, and I want to make sure I'm not missing something.

Thanks,

Here is what we currently have, maybe give you a few ideas

Business name:
Site Visit Team members:
Places and Facilities visited:
Date and time of site visit:
Name of individual(s) visited on site:
Location is accurate with address provided at account opening: yes or no
Location is clean and well maintained: yes or no
Business being conducted is commensurate with state bsuiness purpose: yes or no, if no please comment
What is the customer volume? Please describe in your own detailed words the level of activity at the store (slow, busy.etc)
If customers are conducting transactions, are the primarily using cash or credit?
Is there an ATM on site? yes or no, if yes complete ATM checklist
Please list all cash intensive business activity occurring in the business

Some points to compare to yours, ATM checklist is to determine how they fund and operate ATM or if its 3rd party ran, and we ask for lease agreement.

hope this helps

In addition to those ideas above, our institution also includes:

Hours of Operation: (enhances other questions to determine volume)
Seasonal Considerations for Transactional Volume:
Are wire transfers processed? If so, who is the processor?
Does entity cash checks? If so, for a fee? If so what %?
If check casher, does entity exceed $1,000/day/customer?
Does entity sell Prepaid Access >1k/day/person?
Does entity have AML Program, Policy, or Officer? (yes to any would be taken into consideration for risk purposes)


Also, we've found that simply having our relationship managers that go out to do these site visits knowledgeable about what we do and about BSA in general, it makes the whole process much easier. A little additional training/guidance can go a long way!

Just a few more thoughts to consider

In our area an important question is:

Are there video arcade games present? How many and what sort.

There is a huge illegal gambling problem in our area with such machines.

Besides some of what is listed above, we include a question on signage. Is there signage indicating the business offers check cashing, sells money orders, etc. We list each MSB type of activity with a Yes or No.

Basically, looking to see if the types of activities they told us they do, match up to what is really happening (i.e. looking to see if they offer check cashing but didn't disclose that up front).

You might find some helpful information here:


Forms

Excellent list of suggestions...to the extent possible, make certain your checklist tracks the questions you asked at account inception. For example, the signage issue already noted; e.g. did they tell you the same thing they are telling their customers about cashing checks, sending wires, etc.? There is also an ATM checklist in Banker Tools that could be an "as needed" addition to an MSB checklist.

One client does her visits as a "mystery shopper;" i.e. she does not say she's from the bank, but just goes to the client's place of business, browses, and asks questions a potential customer might ask. She fills out her worksheet on departure. While there are some advantages, my preference would be that the customer knew that periodic visits would take place.

I'll suggest that the check list should be for all NBFI's providing face to face consumer financial services, not just those that you know have reached MSB status. However, as bankers are incredibly reluctant to do site visits, I think few will consider the deepening of the pool to be necessary.

You've all been very helpful. Thank you all so much, and your insight is greatly appreciated!

Great site! Thanks for sharing Retread!