I'm having a problem in which, I am being asked to meet with clients whose accounts I want to close for BSA reasons because the client wants to convince me not to close the account. I am the BSA officer and I don't feel that I should be doing this. I feel it might even conflict with my decision making. Does anyone out there feel the same or am I totally off with this?

I'm in agreement with you. Although who made the decision to close these accounts, you alone? We're closing our MSB accounts but I made sure that the decision wasn't just mine, I presented everything to compliance committee (which consists of all senior mgmt) and the group collectively made the decision to close. The account officer of each account will be giving them a verbal heads up that we'll be closing their accounts and then a letter signed by CEO will be sent.

I agree with both of you. They should meet with the branch mgr or business dev officer.

That's one of the reasons I left retail banking. I hate talking to people...

I've heard this more and more - the account officers and management want to push the responsibility for "Know Your Customer" exclusively onto Compliance/BSA when the people that are in the best position to perform KYC are the same people that are bringing the customer into the Bank and maintaining the relationship.

Ask your management if they require the Loan Review staff to meet with the customer and explain why they are downgrading a loan.

Who knows - we may need to create a position of "Bouncer" for every Bank!

The analogy between an undesirable credit and an undesirable account are similar.

The decision was also asked by my Audit Committee (which consists of BOD and Sr. Mgmt.) As a result, I am hiring 2 additional employees to meet with clients to discuss their activity. I have a BSA Committee and the members are Sr. Mgmt. Collectively as a group, specific high risk accounts are discussed and as a group, decisions are made to retain or close an account. What was difficult, was obtaining additional information from the Account Officer regarding the client's account. The Audit Committee felt that an independent bank representative would not be easily swayed by the relationship or the fact that this is a "Good Customer" theory. Granted, as the BSA Officer, I feel uncomfortable, nor am I trained as an investigator; however, I will be hiring people with such skills.

The part that gripes me is this:

How can we provide proper customer service if we don't "know" the customer?

How can we successfully cross sell products if we don't "know" the customer?

How can anyone honestly get an annual bonus check if they haven't been diligent in providing service to their customer and successfully cross-selling them products?

THAT is the kind of knowledge that is needed when looking at an account.

Perhaps a better to get answers from the account officers is to ask: "Tell me WHY we shouldn't close this account? If you cannot provide a satisfactory and supported explanation of the customer activities, then the account will be closed."

But it's a management decision and one that will probably prove very expensive because as the bank grows, you will have to hire more and more people to be the "independent" representative to handle the volume.

Here's one more thought - any Account Officer that does NOT provide the information on his or her customers will have to share his or her bonus with the BSA Compliance Department!

To synthesize some of the comments above, the only folks who should be capable of providing you with information that might change your mind are your co-workers who know more about this customer than you do. If they don't, then that's on them.

If I was stuck with the meeting, I would start it by saying the decision has been made, it will not change, and the meeting is a formality. That should cut down on the length of the meeting and on any future requests.

Thank you for all your comments. I addressed this issue yesterday and as can be expected I am now at "war" with a particular officer. What can I say, at least now everyone knows where I stand.

CQ, I'll lend you my pitchfork, if you need it.