Does anyone have a form they are willing to share that is given to customers to fill out requesting the customer's estimated monthly deposits, the types of deposits, anticipated frequency of deposits, etc?

How would you use such a form? If you are thinking about creating the documentation to waive CTR filings, your records are the source for that information, not the customer.

That information is a large part of why KYC was defeated before being an official requirement.

hi,

For me a suspect is a suspect (about robbery suspect information)and i estimate that the procedure following don't respect human right and nobody has the right to show on the public international person who are only suspect.
no justiste whitout the respect of procedure.
pascal thuillier-charmet (a private person )

A lot of bankers will probably share TFord's interest in obtaining a "go-by" for a worksheet after they review the FDIC's revised BSA examination procedures:

12 Determine if the bank has adopted account opening and monitoring guidelines that are appropriate for the bank's size, location, products, customers, and strategic focus, including the following:

12A Verifying the customer's source of funds and type of business, as deemed necessary.

12B Determining the customer's expected transactions at or through the bank.

12C Identifying and reporting unusual transactions or activity.

Such queries and recordkeeping are in no way required by CIP, they are remnants of the "KYC" and "extended due diligence" philosophies that regulatory agencies advocated int the past. Regardless of the lack of a mandate in the form of a regulation, they are clearly expected components of an anti-money laundering program.

Thanks Ken, We were recently examined by OBRE and yes this was one of the many expected components they want to see in an anti-money laundering program. They also HIGHLY suggested the following: reviewing cash in/cash out reports for suspicious activity, create a file on the customer and include a copy of the signature card, meet with the customer if suspicious activity was found, visit the location, view inventory, observe customer traffic, take pictures and document findings via memo to file, request business financial statements, obtain a list of vendors for analysis, review checks drawn on all accounts including personal accounts of the business owners, and review non-cash related deposits. If comfortable with activity, document rationale via memo to file. If not file a SAR, follow up in 90 days. Make a decision to close account or keep open. Document file via memo. These files should also be maintained for your exempt customers. OBRE said that a separate anti money laundering department would propably be required to accomplish an effective program.

I made this type questioning a part of the account opening process and it is included in our account application. I disclose our interest in collecting the information as a means of evaluating whether the products they have chosen are appropriate for the type of activity the customer anticipates. I have also explained to the CSR to use the info for cross-selling and for introducing the customer to other employees or areas they may encounter in the future, such as the Wire Transfer department, or who ever may handle debit card/ATM questions. I would be happy to share this application if you are interested.

Try including these questions in your "New Account Interview Sheet", or whatever form you utilize when opening a new account. When asking the customer for this information, do it politely, work it into your conversation. Don't ask the questions as if the customer is on the witness stand.

As I understand the USA PATRIOT Act, we banks now have a responsibility, under EDD, to know our customers like we have never known them before. Those FDIC Exam Guidelines of Oct. 17 spell it out pretty clearly - we are required to know our customer's expected transaction volume, and monitor what we expect to see with what is actually happening...and if we cannot explain the abnormality, that a SAR filing is probable. How many of us are doing this now, and if not, how are we going to do this without gathering information at account opening???

That would be great if you could share your application.

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That would be great if you could share your application.

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TFord - If you will provide your email address, I will email this application to you. You can provide in this thread or using the PM feature.