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#346473 - 04/13/05 07:47 PM 314a question
Anonymous
Unregistered

Our investment arm is a subsidiary of the holding company so they not employees of the bank..so for 314a sharing do they need to register with Fincen to share information with the bank in completing the 314a list.?

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#346474 - 04/13/05 07:51 PM Re: 314a question
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
Sharing comes under 314(b) and to the best of my knowledge is for banks only and does not tie into the 314(a) requests as such.

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#346475 - 04/13/05 09:01 PM Re: 314a question
Anonymous
Unregistered

I guess I am confused.. when we receive the 314a requests, in order to gather the information we request our investment arm to research thier customer records. They are as we are a subsidiary of the holding company. In order for us to make this request and for them to respond, do we both need to register to share information (314b)with each other?

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#346476 - 04/13/05 11:13 PM Re: 314a question
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
With all due respect, I think you need to speak with your compliance officer.

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