Thread Options
|
#116562 - 09/23/03 03:54 PM
Jack Henry Users - System changes
|
Anonymous
Unregistered
|
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?
|
Return to Top
|
|
|
|
#116563 - 09/23/03 04:26 PM
Re: Jack Henry Users - System changes
|
Anonymous
Unregistered
|
We are Jack Henry Users. Where are those fields located.
|
Return to Top
|
|
|
|
#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.
|
Return to Top
|
|
|
|
#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.
|
Return to Top
|
|
|
|
#116567 - 09/23/03 05:31 PM
Re: Jack Henry Users - System changes
|
Diamond Poster
Joined: May 2001
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.
_________________________
Riding the waves of change.....2014
|
Return to Top
|
|
|
|
#116568 - 09/23/03 09:00 PM
Re: Jack Henry Users - System changes
|
Diamond Poster
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-
_________________________
"No problem can withstand the assault of sustained thinking." ~ Voltaire "Sustained thinking gives me a headache." ~Me
|
Return to Top
|
|
|
|
#116571 - 09/25/03 06:08 PM
Re: Jack Henry Users - System changes
|
10K Club
Joined: Sep 2002
Posts: 13,965
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?
_________________________
My Opinions Only
|
Return to Top
|
|
|
|
#116572 - 09/25/03 07:48 PM
Re: Jack Henry Users - System changes
|
Diamond Poster
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?
_________________________
Opinions are mine and never to be taken as legal advice!
|
Return to Top
|
|
|
|
#116573 - 09/25/03 09:28 PM
Re: Jack Henry Users - System changes
|
Diamond Poster
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?
_________________________
"No problem can withstand the assault of sustained thinking." ~ Voltaire "Sustained thinking gives me a headache." ~Me
|
Return to Top
|
|
|
|
#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.
|
Return to Top
|
|
|
|
#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!!
|
Return to Top
|
|
|
|
#116577 - 09/29/03 01:36 PM
Re: Jack Henry Users - System changes
|
10K Club
Joined: Sep 2002
Posts: 13,965
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'.
_________________________
My Opinions Only
|
Return to Top
|
|
|
|
#116578 - 09/29/03 03:43 PM
Re: Jack Henry Users - System changes
|
Anonymous
Unregistered
|
We are a JH user on Banker II. Are these CIP system changes available in Banker II?
|
Return to Top
|
|
|
|
#116579 - 09/30/03 08:09 PM
Re: Jack Henry Users - System changes
|
Power Poster
Joined: Sep 2001
Posts: 6,029
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).
_________________________
Life without Jesus is like an unsharpened pencil - it has no point.
|
Return to Top
|
|
|
|
#116580 - 10/01/03 05:50 PM
Re: Jack Henry Users - System changes
|
Anonymous
Unregistered
|
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.
|
Return to Top
|
|
|
|
#116581 - 10/01/03 05:51 PM
Re: Jack Henry Users - System changes
|
10K Club
Joined: Sep 2002
Posts: 13,965
TN
|
How do you note the sex of the customer by surname?
_________________________
My Opinions Only
|
Return to Top
|
|
|
|
#116582 - 10/01/03 05:59 PM
Re: Jack Henry Users - System changes
|
10K Club
Joined: Jul 2001
Posts: 83,227
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.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com
|
Return to Top
|
|
|
|
#116583 - 10/01/03 06:05 PM
Re: Jack Henry Users - System changes
|
10K Club
Joined: Sep 2002
Posts: 13,965
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'.
_________________________
My Opinions Only
|
Return to Top
|
|
|
|
#116584 - 10/01/03 06:12 PM
Re: Jack Henry Users - System changes
|
10K Club
Joined: Jul 2001
Posts: 83,227
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.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com
|
Return to Top
|
|
|
|
#116585 - 10/01/03 06:16 PM
Re: Jack Henry Users - System changes
|
10K Club
Joined: Sep 2002
Posts: 13,965
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.
_________________________
My Opinions Only
|
Return to Top
|
|
|
|
#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".
|
Return to Top
|
|
|
|
|
|