How to Identify Material Change in ETF Patterns
Answered by BOL Gurus Mary Beth Guard and Jack Holzknecht Bios
Question: One of the red flags (#21) is to identify an account that is used in a manner that is not consistent with established patterns of activity on the
account. I am looking for suggestions as to how I would identify a material change in
electronic fund transfer patterns in connection with a deposit account. Are
they referring to wire transfers only or are they also wanted us to watch ACH and
internal transfers as well? If it pertains to wire transfers only, I am ok
but if it refers to others, I would really appreciate some suggestions.
Answer: It pertains to both wire transfers and ACH and internal
transfers. There is software available that learns a customer's patterns and
looks for deviation. If you don't have such a capability, modify the red flag
before you adopt it so that it reflects what you can actually detect.
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