Are we required to do 314A searches on our credit card customers? I assume we are but I have never seen it mentioned anywhere.

Good question and I don't have the answer - but I would assume not as I think they are looking for deposit accounts when they send out the 314(a)requests.
Perhaps a guru could jump in here and provide the answer.

We search all of the bank's records...deposits, loans, wire transfers, etc. FinCEN's instructions for responding to 314(a) requests, dated 2-6-03, state that for the records search, you would include, deposit records, funds transfers, records of the sale of monetary instruments, loan records, trust dept. records, safe deposit, as well as a few others.

I agree with Starfish's assessment. We also verify against our credit card portfolios.