Skip to content
BOL Conferences
Thread Options
#371188 - 06/09/05 01:37 PM BSA loans
wam57wam Offline
New Poster
Joined: Jun 2005
Posts: 1
re: 103.33(a) How specific must the loan purpose be for this record keeping requirement? Is business line of credit, passbook loan, etc. adequate?

Return to Top
BSA/AML/CIP/OFAC Forum
#371189 - 06/09/05 01:54 PM Re: BSA loans
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Here's a prior thread.

I know the language Anon quotes there was in the FDIC Handbook at one time, but I simply have not been able to find it in the current version. I would encourage you to be as specific as possible; e.g. "passbook" is about the collateral, not the purpose. On the other hand, a revolving line of credit can't really be said to have a purpose, in my estimation.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#371190 - 06/09/05 04:13 PM Re: BSA loans
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I agree with Ken. What's the purpose of the business LOC? If it is daily operating funds, then state that. "Personal" is not sufficient and I have seen that cited by examiners. However, "Medical" is good enough - you don't need to document what kind of operation a person is having.
_________________________
David Dickinson
http://www.bankerscompliance.com

Return to Top

Moderator:  Andy_Z