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#322037 - 02/25/05 01:12 PM BSA Afraid...BSA VERY Afraid!
Anonymous
Unregistered

Well, everything you have been told about the BSA monster is true! Our examiners looked it up one side and down the other, then picked it to pieces. Somehow we made it through, but I think I've lost about 5 years off my life.

That may be a good thing; I won't be a drain on the Social Security system for that long (provided I ever see ANYTHING from my payments at all).

That said, make sure that your BSA program does about everything but biometric scans of your customers and DNA paternity and maternity tests for minor accounts. One example; our examiner expects us to do an OFAC check on the SELLER of real estate taken as collateral for a loan. We will comply with this, but I hope that all our customers don't resort to keeping their money in a sock under the mattress when all is said and done!

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#322038 - 02/25/05 01:50 PM Re: BSA Afraid...BSA VERY Afraid!
Anonymous
Unregistered

Who is your regulatory agency? Also, what were they looking for you to do in the "knowing the normal and expected transactions of your customers"? What did they want in a risk assessment ??? YIKES.

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#322039 - 02/25/05 02:01 PM Re: BSA Afraid...BSA VERY Afraid!
P*Q Offline

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P*Q
Joined: May 2001
Posts: 8,458
Somewhere
We had an FDIC exam back in December and I thought it wasn't bad at all, nothing I didn't already expect based on the pre-exam checklist. I think the issue exists where there is not consistency between regulators and I've even heard from other FDIC Banks whose experiences were very different from mine so no one can fully know what to expect until they're on site.

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#322040 - 02/25/05 02:36 PM Re: BSA Afraid...BSA VERY Afraid!
BankerMama Offline
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BankerMama
Joined: Jun 2001
Posts: 1,543
Well everyone I have talked with who is regulated by the FDIC thinks it wasn't too bad. Let me tell you....the Federal Reserve is a whole different ballgame. Why the difference? Beats me but it isn't fair in my opinion.

Anon thinks it took about 5 years off his/her life----so did it mine. Plus it caused me to gain weight, affected my health AND just about turned me against banking altogether. This comes from a BSA officer that had never received anything but exceptional examinations. I don't like this political mess we're caught in the middle of one little bit.

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#322041 - 02/25/05 03:03 PM Re: BSA Afraid...BSA VERY Afraid!
Anonymous
Unregistered

Original poster - are you regulated by the OTS? In a discussion with a Field Supervisor at the Atlanta OTS office in mid-Jan. he said there had been discussion among the regulators and OFAC of this exact requirement. I sort of lost my cool with him and asked just where is this going to end - is the next step having to review the payee on all our customers checks, whether a deposit account payment or a home equity advance? He was a bit sympathic and indicated that he too really didn't know just how far it was eventually going to go!

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#322042 - 02/25/05 03:04 PM Re: BSA Afraid...BSA VERY Afraid!
Anonymous
Unregistered

OTS. As for customer transaction monitoring, lower you report threshold from $10,000 to $3,000 to 5,000 and make sure you have a procedure in place that (highlevel) speaks to who monitors customer transactions and what they are watching for.

"YIKES" is right!

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#322043 - 02/25/05 03:06 PM Re: BSA Afraid...BSA VERY Afraid!
Anonymous
Unregistered

Original anon here. Bankermama, I couldn't agree with you more! I have about decided to sign on for the new FinCEn department so I can be the one instilling fear, instead of being the one in whom the fear is being instilled!

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#322044 - 02/25/05 03:14 PM Re: BSA Afraid...BSA VERY Afraid!
Anonymous
Unregistered

Yes OTS. Above all else, keep your cool! They are probably being come down on hard to ensure that banks are doing as much as possible in their BSA and OFAC compliance. In the absence of any interagency guidelines, I imagine that some of what we are receiving as recommendations may end up being left out. I think the interagency guidelines wil be coming out in the next month or two.

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#322045 - 02/25/05 06:00 PM Re: BSA Afraid...BSA VERY Afraid!
Princess Romeo Offline

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Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Let me tell you, OCC BSA exams are not a walk in the park either.

We had 7 examiners for about 2 1/2 weeks (to be fair, not all 7 were on sight the entire time) and this was a CONTINUATION of an exam that started back in September with 1 examiner for about 2 1/2 weeks. That makes it almost a 5 week exam, and we are only about $1.7Billion.

Thank goodness in between the start and the conclusion of the exam we were finally able to hire an experienced BSA Officer to focus solely on BSA. (And yes - CRA and HMDA filing are not done yet...but should be today....)

Our exit interview is this coming Monday. Please say a little prayer for me and my department.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

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#322046 - 02/25/05 06:30 PM Re: BSA Afraid...BSA VERY Afraid!
Anonymous
Unregistered

I went through a BSA exam by the OTS during the third quarter last year. They interviewed me and told me that any violation found must be corrected before they leave or we get a management letter. We had no issues. OFAC was not even looked at because they reviewed it during the prior year. So what they are saying is that OFAC checks have to be done on sellers that are not the customer? So when will we have to check out their seller and so on? They focused on me and what I do, the frequency, and my knowledge of the regulation. Document everything you do. Oh, were you told that you have to give them everything electronically? We did more that once. One examiner didn't want to open and read the documents on his laptop, so we had to print everything too. I also went through a FRB BSA exam a few years back. These guys were crazy. It was very stressful. I don't want to know anyone as well as they expect us to. If they know so much they should be telling us how to do this stuff. Not intiminating us.

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#322047 - 02/25/05 06:36 PM Re: BSA Afraid...BSA VERY Afraid!
Retired DQ Offline
10K Club
Retired DQ
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
Quote:

Oh, were you told that you have to give them everything electronically? We did more that once. One examiner didn't want to open and read the documents on his laptop, so we had to print everything too.




Hmmm, I wonder if I had the same guys at my shop... The same thing happened.
_________________________
Get your facts first, then you can distort them as you please. - Mark Twain

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#322048 - 02/25/05 07:10 PM Re: BSA Afraid...BSA VERY Afraid!
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
We are OCC regulated and have been told by our portfolio manager to expect 4-5 examiners for 2-3 weeks over the summer and that the exam will be "rigorous".

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#322049 - 02/25/05 07:14 PM Re: BSA Afraid...BSA VERY Afraid!
Anonymous
Unregistered

Original anon again. Not quite as picky here, but thorough. Yes, I agree, I feel as if they expect us to follow certain customers home and spy on them.

I agree that it is reaching the point where they need to just hand us their workpapers and say, "Do it this way and ONLY this way!"

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#322050 - 02/25/05 07:41 PM Re: BSA Afraid...BSA VERY Afraid!
Anonymous
Unregistered

We just wrapped up a three week BSA exam by the OCC and they're coming back later to wrap up! Extremely frustrating and unfair is the only way to describe it. Their expectations are wholly unreasonable and not required by any regulation. We're fighting their findings "to the death" (although I'm not sure whose death).

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#322051 - 02/26/05 12:13 AM Re: BSA Afraid...BSA VERY Afraid!
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Comment letters people.....comment letter!!! Support the BOL comment letter and then write one of your own.

Someone needs to tell the Greenlining Institute that the BSA exams threaten to undo a lot of the Community Development programs they have worked (threatened) so hard to get in place at banks.

Lord Palmerston was right - There are no permanent allies. There are no permanent enemies. Only permanent interests.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

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