We added the IAT information to our OFAC Policy. It is about three paragraphs long: the first one explains what an IAT is which we "took" from NACHA. The second paragraph explains that we are an RDFI and that we will review all parties involved in the transaction. We stated that at this time we are not an ODFI but if we were, we would review all parties and remittance data. Then in the last paragraph we explained what our processor will be giving us and how we use Bridger to check all parties. Documention procedures and retaining is also included.
We didn't need to add if and OFAC name appeared since it was already in our policy. Any findings, whether it's a wire or a new loan customer, has the same policy/procedure.
Hope this helps a little
We know that we may have to revise ours once we know what to expect.