Help !!!... In the last 2 weeks we have received 2 forms from banks asking us to certify certain information ( we have a BSA program, last approved by board, whether we are in drug trafficing area... etc.) the only relationship we have with each of these banks is through a loan participation agreement and we wire payments.. I am aware of foreign bank correspondent certifcation requirements.. but we are a domestic bank.. Is there something new out there that I have missed.. or is this overkill on these banks part?

IMHO - Overkill.

thank you, that was my original thought as well... or both attended a seminar that recommended an extra cautious approach to correspondents.

Actually, its the correspondent bank that needs to be careful. It's the one that takes the risks if its respondents are not up to snuff with their BSA/AML efforts.

It's analagous to some other relationships today; i.e. your protection is no better than your partner's.

yes, that is true, however, in this case the only relationship we have is wiring payments on a participation loan.. the participating bank had the opportunity to perform any procedures normally followed on opening an account before committing to the participation..

I wasn't suggesting I thought sending out these letters was worthwhile based on the facts you described earlier. I was only pointing out that the caution is due respondent banks; a bank that provides correspondent services generally doesn't pose a compliance threat to the banks to which those services are provided.

I see your point, thank you!

This is actually rather common. Larger banks frequently require this of all banks they deal with down the food chain, rather than having to determine on a case by case basis when it is needed. They make it one size fits all and ask the banks to attest to their programs.