Does due diligence require asking 'Does this revenue derive from marijuana related activity?'
Do Patriot Act Notices and UBO notices have to be on the bank website? We do not open accounts online at this time.
If Bank receives a copy of a DL for a Beneficial Owner that has a different address than supplied on the collection form or the Bank is only provided a passport with no address, would we need to collect other documents to prove address and/or social? I feel like we would be criticized for only being able to verify two out of four pieces of identification.
During a recent FDIC exam I was asked for the proof that I am doing some kind of due diligence on the loans that we are purchasing a share of through participations. I happen to have sent a compliance warranty last year, because I had heard some chatter on this. My question is, 1. does it state this requirement anywhere in regulation 2. Does this have to be re-certified annually? 3. Can an acknowledged statement on the loan documents signed by an officer of the other bank take the place of a formal letter?
How do I start preparing for the new Beneficial Ownership/CDD rules?
Does the new CDD for Beneficial Ownership play into a participant loan? How would you get this information?
Is there a better way to show due diligence on missing documents?
How much due diligence is required to effectively manage the risk of banking MRBs?
We have many customers that deposit a lot of cash. How do we determine if the amount is reasonable?
What are the key things I should look at when researching a compliance management system?