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#116562 - 09/23/03 03:54 PM Jack Henry Users - System changes
Anonymous
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Question for Jack Henry users. We were looking at the CIP system changes from JHA. Are you using the risk rating code field? If yes, what are the codes and descriptions being used?

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#116563 - 09/23/03 04:26 PM Re: Jack Henry Users - System changes
Anonymous
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We are Jack Henry Users. Where are those fields located.

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#116564 - 09/23/03 04:44 PM Re: Jack Henry Users - System changes
Anonymous
Unregistered

In the CIF Parameter Maintenance Menu and CIF Maintenance menu. We just got our CD-ROM installed last night. Today was the first time we could see the fields.

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#116565 - 09/23/03 05:02 PM Re: Jack Henry Users - System changes
Anonymous
Unregistered

We are a JH user and I personally think they wasted their time on this risk rating stuff. As far as CIP is concerned, the risk has to do with what we do up front to verify a customers identity. In other words if the customer is a check cashing company, we would require more verification than if it was an individual opening a checking account, etc. We are not using it and never will.

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#116566 - 09/23/03 05:05 PM Re: Jack Henry Users - System changes
mrenderman Offline
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mrenderman
Joined: May 2003
Posts: 123
Wisconsin
Are you at least using the ID verification field and the date it was verified so that all users can see that the customer has already gone through the CIP process? We are not going to use the risk fields either but we are utilizing the ID and ID date fields.

Michelle R.

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#116567 - 09/23/03 05:31 PM Re: Jack Henry Users - System changes
La. Lady Offline
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La. Lady
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Posts: 1,873
We are not using that risk assessment. As stated in earlier posts....risk based is subjective.

We are using the SIC code #4. On our system it was blank. We put "CIP VERIFIED". Now when the employee performs a Customer Information Inquiry, it appears on the screen listing "messages-VIP Customer-Employee", etc.
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#116568 - 09/23/03 09:00 PM Re: Jack Henry Users - System changes
GenerousLife Offline
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Joined: Feb 2002
Posts: 1,466
USA
We just got our documentation today. Right now we don't think we will use the Risk Rating portion. We were wishing for an additional free form area so we could put all of our CIP documentation/verification/discrepency resolution information and avoid retaining paper copies of anything. -Sigh-
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#116569 - 09/23/03 09:21 PM Re: Jack Henry Users - System changes
conniew Offline
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conniew
Joined: Apr 2002
Posts: 155
St. Louis, MO
Kat-
That's an excellent suggestion. I just asked our IT person to edit an unused SIC field for that same purpose. Thanks!

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#116570 - 09/23/03 09:22 PM Re: Jack Henry Users - System changes
mrenderman Offline
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mrenderman
Joined: May 2003
Posts: 123
Wisconsin
Boy, I am thinking you are one of those who want your cake and eat it to. That would be way too easy for a computer company to conform to regulations in order to make our life easier. Actually I was hoping for the same thing, but I guess I will settle for what we got, its better than nothing at all.

Michelle R.

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#116571 - 09/25/03 06:08 PM Re: Jack Henry Users - System changes
Skittles Online
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TN
I now have another Jack Henry question. In training this morning I discovered that we are required to indicate the sex of the customer. This concerns me due to Regulation B. We are considering noting everyone as male. How do the rest of you handle this situation?
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#116572 - 09/25/03 07:48 PM Re: Jack Henry Users - System changes
BBoyd Offline
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BBoyd
Joined: Mar 2002
Posts: 2,494
MI
We're using the Risk Rating codes, and can set whatever ones we want. We've chosen P1 to P5 for personal, and B1 to B5 for business; 1 being all documentation received and verified; 5 being WHY ARE YOU OPENING THIS ACCOUNT? (No documents, nothing verified.) We also have added some for those we know we don't have to verify - like Authorized signers on a business account, vendor accounts, etc. We've also linked the Multi-ID screen to appear when a risk rating code is entered - RR code is required.

We didn't find that gender was required - where is that being keyed in?
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#116573 - 09/25/03 09:28 PM Re: Jack Henry Users - System changes
GenerousLife Offline
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Joined: Feb 2002
Posts: 1,466
USA
Regarding your question on requiring the Sex Code: According to my documentation the CFSEX field is "NOT REQUIRED". Perhaps that is something internal to your bank?
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"Sustained thinking gives me a headache." ~Me

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#116574 - 09/26/03 02:20 PM Re: Jack Henry Users - System changes
Anonymous
Unregistered

Our bank is a JHA client, and we are not using the risk fields. By the way, I think JHA deserves kudos for the way they run their business. They keep on top of regulatory issues, and they do work to meet everyone's needs. Their people are always helpful and usually get problems resolved quickly. When it comes to conversions and upgrades, I have never had a better (meaning fewer problems!) experience with any other data processing vendor.

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#116575 - 09/26/03 04:16 PM Re: Jack Henry Users - System changes
Anonymous
Unregistered

Yes, Jack Henry Systems does do a better job in most cases, however, they blew this one. They should have requested input from compliance professionals or at least someone who had actually read the regulation!!

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#116576 - 09/26/03 05:04 PM Re: Jack Henry Users - System changes
LSmith Offline
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We are a JHA user but are not using the risk codes. If it is risky, we are not opening the account anyway. We are using the ID codes for ID (Identified) and UN(for Unidentified) We are also coding all present accounts GF for Grandfathered. On inquiry all you have to do is do an F4 for ID and look to see the code then we do an F19 to see the silhouette image of the documentation. We are scanning our documentation.

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#116577 - 09/29/03 01:36 PM Re: Jack Henry Users - System changes
Skittles Online
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TN
Ours is in the CIF setup screen on 20/20. I spoke with one of their compliance people and they said it was for required reporting for Regulation B and that it was permissible to ask the customer their sex, but they didn't have to provide it. I totally disagree and we're still going to list everyone as 'male' or 'other'.
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#116578 - 09/29/03 03:43 PM Re: Jack Henry Users - System changes
Anonymous
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We are a JH user on Banker II. Are these CIP system changes available in Banker II?

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#116579 - 09/30/03 08:09 PM Re: Jack Henry Users - System changes
BrendaC Offline
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Sweet Home AL
We are not using the risk rating codes. I do not want to start a program that could be far too labor intensive to manage down the road.

I want to generate some type of report that will help to identify missing information on CIP required fields. In looking at the new CIP report documentation, it does not appear that we will be able to get an exception report without writing a special report. I think I am going to request a daily report identifying the following information on each new CIF created: name, address (including IRS street address), DOB, ID fields and Special Information Code 5 (Identity Verified should equal yes).

I also want a report from 10/1/03 forward identifying any CIF with SIC Code 5 = No. Everyone from 10/1 forward should be verified (that means we will have a customer ID form completed and on file).
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#116580 - 10/01/03 05:50 PM Re: Jack Henry Users - System changes
Anonymous
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Quote:

In training this morning I discovered that we are required to indicate the sex of the customer. This concerns me due to Regulation B. We are considering noting everyone as male. How do the rest of you handle this situation?




Regulation B states that you shall ask. The customer does not have to provide the information. If they don't provide it, the lender will note that and then indicate the requested information, to the extent possible, on visual observation or surname.

I don't think that using "male" and "other" is to the extent possible.

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#116581 - 10/01/03 05:51 PM Re: Jack Henry Users - System changes
Skittles Online
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TN
How do you note the sex of the customer by surname?
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#116582 - 10/01/03 05:59 PM Re: Jack Henry Users - System changes
rlcarey Online
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Galveston, TX
Quote:

Regulation B states that you shall ask. The customer does not have to provide the information. If they don't provide it, the lender will note that and then indicate the requested information, to the extent possible, on visual observation or surname.




You need to qualify this - this only applies if the loan is subject to the monitoring information gathering reguirements of Reg B or HMDA or for use in a self-test.

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#116583 - 10/01/03 06:05 PM Re: Jack Henry Users - System changes
Skittles Online
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TN
That's what I thought and our FDIC examiner couldn't think of any reason it was required with the exception of HMDA reportable loans. That is why we're going to list everyone as 'other'.
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#116584 - 10/01/03 06:12 PM Re: Jack Henry Users - System changes
rlcarey Online
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Galveston, TX
Why make it a required field? Why not just leave it blank? Otherwise you are setting yourself up for problems with non-compliance to bank policy and opening the door for Reg B violations.
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#116585 - 10/01/03 06:16 PM Re: Jack Henry Users - System changes
Skittles Online
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TN
We didn't make it a required field - Jack Henry did. I discussed this with their compliance person who told me it's for reports for Reg B purposes. I informed her that there are no requirements and that we were just examined and weren't written up for not writing these reports. She wanted to kind of argue with me and I just dismissed her and said we would figure a way around it. I guess I got a little rude, but not too bad. We are trying to figure out if we can default everyone to 'other' without our staff having to input something in that field.
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#116586 - 10/01/03 06:40 PM Re: Jack Henry Users - System changes
Anonymous
Unregistered

Skittles, what version of Jack Henry are you using. I don't see anything about a required field for "sex".

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