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#1276600 - 10/28/09 09:40 PM UIGEA - Question
Islandgirl Offline
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Louisiana
Our bank has a separate policy and procedures for UIGEA. Are any of you putting anything about UIGEA in any of your other bank policies such as (Wire Transfer Policy, ACH Policy, BSA/AML Policy or OFAC Policy)?

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#1276620 - 10/28/09 10:09 PM Re: UIGEA - Question Islandgirl
Rob K Offline
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Rob K
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Tennessee
We have chosen not to reference our UIGEA Policy in any other bank policies.
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#1276623 - 10/28/09 10:16 PM Re: UIGEA - Question Islandgirl
Elwood P. Dowd Offline
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Next to Harvey
Whether it's the "red flags" or Regulation GG, you greatly elevate the importance of a topic when you incorporate it into your BSA/AML policies.

You can tweak your due diligence and enhanced due diligence questions in such a way as to elicit the information you need without mentioning Regulation GG in any way.
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#1276644 - 10/28/09 11:57 PM Re: UIGEA - Question Elwood P. Dowd
BetsyS Offline
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We've added it to our Credit & Card Debit Card Program policies, mostly to document how we're blocking those transactions. We've also added it to our Merchant Bankcard Acquiring Program policy.
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#1276835 - 10/29/09 03:21 PM Re: UIGEA - Question BetsyS
PBAllDay Offline
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PBAllDay
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Wisconsin
We have added it to our signature cards.
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#1277450 - 10/30/09 02:21 PM Re: UIGEA - Question Islandgirl
Islandgirl Offline
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Louisiana
Thanks for the replies.

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#1281764 - 11/05/09 06:36 PM Re: UIGEA - Question Islandgirl
Wisco Crime Stoppers Offline
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Wisco Crime Stoppers
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Packer Country
Is it required to be added to account opening disclosures like the signature card or deposit account rules, etc.?? I can't find anywhere that it states it 'has' to be. Just wondering if our disclosure need to be updated or if a handout at account opening is sufficient. thanks
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#1281779 - 11/05/09 06:42 PM Re: UIGEA - Question Wisco Crime Stoppers
waldensouth Offline
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We use Wolter's Kluwer signature cards and those terms and conditions have been updated to include the language. why have another piece of paper to hand out? Nothing says they have to be included in the sig card, just that it must be provided to everyone opening a new account after 12-1-09.
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#1281970 - 11/05/09 08:20 PM Re: UIGEA - Question waldensouth
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Originally Posted By: waldensouth
We use Wolter's Kluwer signature cards and those terms and conditions have been updated to include the language. why have another piece of paper to hand out? Nothing says they have to be included in the sig card, just that it must be provided to everyone opening a new account after 12-1-09.

For business accounts or for all? Just curious!
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#1281986 - 11/05/09 08:39 PM Re: UIGEA - Question waldensouth
J2C Offline
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Big Brother knows and that's a...
Originally Posted By: waldensouth
We use Wolter's Kluwer signature cards and those terms and conditions have been updated to include the language. why have another piece of paper to hand out? Nothing says they have to be included in the sig card, just that it must be provided to everyone opening a new account after 12-1-09.


WK provided us with a seperate disclosure statement that needs to be signed at account opening for business customers. They did not indicate to us that it had been added to the signature card documents?? Hmmm.
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#1282031 - 11/05/09 08:59 PM Re: UIGEA - Question J2C
#Just Jay Offline
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Cheeseheadland
CSi has included veribage in both the business account master agreement, as well as the account agreement.
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#1282083 - 11/05/09 09:42 PM Re: UIGEA - Question Kathleen O. Blanchard
waldensouth Offline
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FINALLY ABOVE the gnat line
Originally Posted By: MS Kaybee
Originally Posted By: waldensouth
We use Wolter's Kluwer signature cards and those terms and conditions have been updated to include the language. why have another piece of paper to hand out? Nothing says they have to be included in the sig card, just that it must be provided to everyone opening a new account after 12-1-09.

For business accounts or for all? Just curious!


They added it to the terms and conditions for everyone!
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"Once you learn to read, you will be forever free."

- Frederick Douglass




My Opinion Only.

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#1282133 - 11/05/09 10:17 PM Re: UIGEA - Question waldensouth
Happy Offline
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Are you talking about the Form MPSC-LAZ? What section did they put it in?

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