I have an issue that some of our tellers are not understanding. Tell me from the compliance standpoint of CIP how this should be handled. We have always required ID on all people, customersif you do not know them and noncustomersno question. However, some tellers are not asking for ID on noncustomers because they have been coming into the bank for the last 5 years to cash their check so they do not get their ID. How do you suggest we handle this situation?
Under CRA, what constitutes a commercial or Industrial purpose? I have looked for a definition to no avail. Would this include a loan to a small business for a capital injection?
Where on the call report will I find the RSSD ID Number?
In a training last week it was brought to my attention on the new CTR form that it is requiring the ID collection of an entity. In the past this has never been the case and in the FFIEC manual it specifically refers to individuals. FinCEN has said that there is nothing new to the forms except the collection of the new fields. Not in any webinar or documents that we received from FinCEN said anything about identifying document collection of an entity for a CTR. The only thing I have seen regarding this is actually on the form from the help box in the ID field itself. Is this something we have to collect going forward?
Currently I am acting as BSA/OFAC Officer, Branch Manager and Loan Officer. Our state/federal regulator just examined our BSA Program and has made mention that she feels like this is an internal control issue. They are recommending that if I need to wear more than one hat it needs to be a different job duty other than branch manager and loan officer. Is this stated anywhere that I can reference the internal control issue for my board of directors? I have reviewed the FFIEC manual and it does not address this direct question.
Where do I go to find a good definition of "best practices" for a new employee as it relates to BSA/AML?
Is it my understanding that when a doctor is placed on our high risk list that they remain there permanently since it is a service based industry?
We are being told by our internal auditors that a customer in which we have CTR exempted should be removed from exemption status due to negative information that they found regarding the customer that they found on an Internet search that dates back to 2000. When we performed our due diligence to exempt the customer last year we performed our due diligence and maintained records in accordance with FFIEC BSA/AML CTR exemption guidelines. There were no abnormalities noted at that time. The reasoning our auditors are referencing is that this customer poses a higher risk and should be removed as "Best Practices". Has anyone every experienced this?
I have noticed that the Rate Yield Table on the FFIEC website has not been updated since 9/15/11. This is where we get the table from for HOEPA loan calculations. Do you know if it has been moved or changed?
Is CRA purpose driven or collateral driven?