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#251015 - 09/30/04 03:37 PM
Re: BSA EXAMINATION!!!
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10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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I have one PM me your email.
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Get your facts first, then you can distort them as you please. - Mark Twain
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#251016 - 09/30/04 05:40 PM
Re: BSA EXAMINATION!!!
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Anonymous
Unregistered
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Our 314 procedures are written into the Pariot Act portion of our BSA policy. We had a Fed exam in the summer and were not criticized.
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#251017 - 09/30/04 05:51 PM
Re: BSA EXAMINATION!!!
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Diamond Poster
Joined: Jun 2004
Posts: 1,975
Alderaan
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I've seen them incorporated as well. Ours happen to be separate.
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#251018 - 09/30/04 07:37 PM
Re: BSA EXAMINATION!!!
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Power Poster
Joined: Apr 2001
Posts: 4,828
Between the lines
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BUT, is it required that there be a written policy and procedures?
Thanks,
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#251019 - 09/30/04 07:44 PM
Re: BSA EXAMINATION!!!
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10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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I don't think a policy is required, per se, I never saw such a requirement. However, for consistency and proof of doing the checks, we have procedures in place.
It is included in our BSA manual, not our BSA policy.
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Get your facts first, then you can distort them as you please. - Mark Twain
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#251020 - 09/30/04 08:05 PM
Re: BSA EXAMINATION!!!
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New Poster
Joined: Jun 2004
Posts: 7
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we were just told last week by the FRB that we must "devise a 314 (a) policy"
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#251021 - 09/30/04 08:20 PM
Re: BSA EXAMINATION!!!
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100 Club
Joined: Dec 2003
Posts: 102
West Coast
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Since we're on the subject....can anyone give me some ideas on what your doing to check your Cashiers Checks, Money Orders and Travelers Cheques?
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#251023 - 09/30/04 10:58 PM
Re: BSA EXAMINATION!!!
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Power Poster
Joined: Apr 2001
Posts: 4,828
Between the lines
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nearly compliant, kindly ask your examiner to reference where it says that you must have a "policy". When you tell management that you have to have a policy, they are going to ask you to prove it--most examiners are very helpful in providing this back-up for you. Sometimes it's just a matter of, "Yea, I know I called it a policy, but I really just mean that you have to have it written."
Policies require board approval and next thing you know, you could be in compliance with the law and out of compliance with your own policy. Program, procedure, OK, these are a lot easier to update as changes are needed.
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NOLA is my Beach!
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#251025 - 10/01/04 11:00 AM
Re: BSA EXAMINATION!!!
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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banker mama,
Compliance with 314(a) requirements is an element of your BSA compliance program; i.e. you should address 314(a) compliance in your BSA policy just as you do CTR filing, record retention, etc. They are not looking for a separate set of policies and procedures, they only expect to see the issued addressed as a part of a comprehensive BSA effort.
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#251027 - 10/06/04 05:05 PM
Re: BSA EXAMINATION!!!
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Anonymous
Unregistered
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I am being asked for my 314 B policy. When I mentioned we do not share and that such sharing is voluntary under the act, the examiners recommended that we add to the BSA policy a statement or two discussing that we do not share. Also, by the way, last year I was told to write a 314 A policy and procedure, which I did and included in the BSA policy manual. I guess I'd rather have these types of recommendations rather than< "Gee, we found these accounts held by Pinochet at your bank in an offshore PIC account"  There is always something that is said or recommended.
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#251029 - 10/06/04 06:26 PM
Re: BSA EXAMINATION!!!
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10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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Quote:
Devil Girl, I emailed you asking if you can share your policy but haven't received any reply.
Did you get my email?
Banker Mama, I thought I sent it to you, I am sorry, PM me your email address, I must have sent it to someone else...
I have had meetings every day this week, and I am moving to my new office on Friday, but of course, I have a meeting that morning, too...
 
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Get your facts first, then you can distort them as you please. - Mark Twain
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#251030 - 10/06/04 06:35 PM
Re: BSA EXAMINATION!!!
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10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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Hey Banker Mama,
I just checked my sent items, I think that I sent you an empty email... I just resent it with the attachments (I hope it is you..., you are not accepting PMs)
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Get your facts first, then you can distort them as you please. - Mark Twain
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#251032 - 10/09/04 03:57 PM
Re: BSA EXAMINATION!!!
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Diamond Poster
Joined: Feb 2001
Posts: 2,245
US of A
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Quote:
Our firewall must be blocking because I have not received anything at all by PM or email.
Mama,
If you change your profile to accept private messages I'll send you a text version of ours right in the message. That way you won't have to worry about your firewall.
I tried to PM you, but your profile says you don't accept messages.
-- Homestar
P.S. If you decide to change your profile, just send me a PM to let me know.
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"If you want to tell people the truth, make them laugh, otherwise they'll kill you." ~ Oscar Wilde
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#251033 - 10/27/04 07:25 PM
Re: BSA EXAMINATION!!!
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100 Club
Joined: Dec 2002
Posts: 193
Tennessee
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Homestar, Devil Girl...and anyone else out there in "Compliance Land"...
I would also appreciate it greatly if you could send me a copy of your information...I should be set to receive PM's.
If you have any trouble doing that, please post to that effect, and I will try to fix that or come up with Plan B.
Thank you in advance...we have a pending exam, and it's probably obvious from this and other posts that I have made, that I am a newbee...if I were any more green, I would blend in with the grass!
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#251034 - 10/27/04 07:41 PM
Re: BSA EXAMINATION!!!
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10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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Mike, I emailed you...
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Get your facts first, then you can distort them as you please. - Mark Twain
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#251035 - 10/27/04 07:48 PM
Re: BSA EXAMINATION!!!
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Anonymous
Unregistered
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Thank you very much! I appreciate your sending it, and responding so quickly.
I am very thankful to have the resource in Bankers Online, and the expertise of yourself and others.
Have a great afternoon!
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#251036 - 10/27/04 08:58 PM
Re: BSA EXAMINATION!!!
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Gold Star
Joined: May 2004
Posts: 352
Alabama
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Quote:
Since we're on the subject....can anyone give me some ideas on what your doing to check your Cashiers Checks, Money Orders and Travelers Cheques?
We are a Jack Henry bank using Vertex for our teller automation. For cashiers checks, I run a Query report against the cashiers check file on the AS/400. I list all non-customer sales for transactions between $3k and $10k for the previous 6 months. We then check the report against the 314(a) requests. We don't have a lot of non-customer sales, so the manual verifying is not too difficult.
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#251037 - 11/01/04 02:59 PM
Re: BSA EXAMINATION!!!
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Member
Joined: Jun 2004
Posts: 93
NC
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Devil Girl - I'd appreciate a copy, too; if you don't mind. I'm pretty sure I'm set up to receive PMs. Thanks!!
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#251038 - 11/01/04 04:13 PM
Re: BSA EXAMINATION!!!
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Gold Star
Joined: Oct 2004
Posts: 327
Upstate N.Y.
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Devil Girl, could you PM me a copy of your procedures? Thanks.
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#251039 - 11/01/04 06:11 PM
Re: BSA EXAMINATION!!!
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New Poster
Joined: Oct 2004
Posts: 11
Texas
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I need to make sure I understand. On outgoing wire transfers do we need to check the name of the beneficiary and on incoming do we need to check the name of the originator.
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#251040 - 12/03/04 03:57 PM
Re: BSA EXAMINATION!!!
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Anonymous
Unregistered
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We got examined and they cited us for lack of 314a searches on beneficiaries of outgoing wires and originators of incoming wires. We argued with them and they backed down. So, I guess the real answer is, "No, it is not required, but you may have to argue."
Also, be sure you do an OFAC search on ALL parties to wire transfers. (They even indicated that we should search the intermediary bank! We refused on common sense grounds unless it was a foreign bank.)
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#251042 - 02/10/05 09:09 PM
Re: BSA EXAMINATION!!!
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Member
Joined: Feb 2005
Posts: 63
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Could I get a copy of that 314 (A) policy or procedure? Thanks a lot - my email is matt@capitalcombank.com if you could send it as an attachment
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#251043 - 02/10/05 09:13 PM
Re: BSA EXAMINATION!!!
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Member
Joined: Feb 2005
Posts: 63
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We are being examined right now, and are being cited for not checking 314(a) on wires....is there any reasoning that I can use in arguing the citation?
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#251044 - 02/10/05 09:21 PM
Re: BSA EXAMINATION!!!
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Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
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If you do not do wires (in or out) for non-account customers you do not need to check wires separately vis-a-vis 314a since this will be checked when you check your CIF. Hope this helps. If you do wires for non-account customers, you need to check.
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#251045 - 02/10/05 09:47 PM
Re: BSA EXAMINATION!!!
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Anonymous
Unregistered
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Can't argue not checking non-acct wire transfers. They have to be checked. Nothing you can do but draft up a policy/procedure for checking 314a requests against your non-acct wires, and wait for that good'ol examination train to rool around.
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#251046 - 02/11/05 12:33 PM
Re: BSA EXAMINATION!!!
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10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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Matt, I PM'd you... must have email address, must have email address... 
_________________________
Get your facts first, then you can distort them as you please. - Mark Twain
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