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#1050541 - 09/25/08 05:47 PM Red Flag documentation in file
Tessie Offline
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Joined: Jan 2006
Posts: 155
When we open a new accout, loan, CD, etc do we have to keep a copy of the 26 Red Flag checklist in the file to show we did not find a red flag, or do we use this only when we detect a red flag?

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#1050649 - 09/25/08 07:07 PM Re: Red Flag documentation in file Tessie
AuditorK Offline
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Posts: 961
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I would prefer to only complete the checklist when a red flag is detected - less paper, less time, less chance of forgetting, etc. The consultant that worked with us recommended completing the checklist for all new covered accounts - to show we are looking for the red flags each time. I'm still not sure which way we'll go. I'm leaning towards only putting a copy in the file when a flag is detected. If that isn't sufficient, our examiners or just plain best practices will let us know we need to do differently.

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#1051116 - 09/26/08 01:42 PM Re: Red Flag documentation in file AuditorK
Maytagman Offline
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Checklist? Why? Why create documentation to show that you didn't notice something? On the other hand, we have a CIP sheet that now includes the credit freeze, fraud alert, and active duty alert, so I guess we are keeping something comparable for the particular ones that apply to notices from a credit reporting agency. Does your checklist cover all 26 flags?
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#1051489 - 09/26/08 04:09 PM Re: Red Flag documentation in file Maytagman
AuditorK Offline
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Our checklists are product specific, so no, not all 26 red flags are applicable to each product. I agree on your assessment of not keeping a checklist to show that we didn't encounter a red flag, but its a good way to document compliance. We can show that the red flags were in front of the persons opening the accounts each and every time. I suppose procedures/training could take the place of the checklists. I'm just hesitant at this point.

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