I have been doing the 314a reviews right along with our current database everyother week. Our examiners say we need to search all parties involved with wires. We would include our own customers as part of the search, but not the all parties to a wire...I don't have a clue how to do that, any suggestions??

Thanks

So, the #2 under question #5 just says that we need to check the beneficiary or originator IF it's not our customer? We are a credit union so we do not perform txns for non-customers/members. Thanks for the clarification.

Do your members only send wire to other members?

No, but item #2 says "funds transfer records....a named subject was an originator of a funds transfer for which the bank was the originator, or a benficiary of the a funds transfer for which the bank was the beneficiary". I take that as saying an originator (member) for which the bank was the originator, we screen members for 314(a). Then the second part - the beneficiary of the funds transfer for which the bank was the beneficiary, again our member is the beneficiary. Am I missing something?

Beachgirlatheart, I'm with you. Originator on wires originated through you or beneficiary on wires where you were the receiving bank. You're covered by searching your customers as long as wires are sent or received for your customers/members only. If you're missing something, I am too.

We send wires to other non-members from our members, but that still isn't required to be searched. Either way you slice it there is not a requirement to run a 314(a) search on other people who receive the wires (non-members)....

Yeah, nix this... I had my head up my arse and was on a different thinking course (reading too fast while trying to pay attention to something else as well)... totally concur with you as well.