I know the Feds postponed implementation of this one for a while. We all prayed it would go away. Prayers not answered. Did the Fed ever come out with any clarification to some of the issues brought up by numerous Compliance types or did they just.....wait and then dropped their bomb again. Same bomb.

The bomb is the same. It hits on June 1. Congress has failed to do anything about the law. The Fed and Treasury are stuck with implementing the regulation.

Great!

Can we notify existing commerical customers on their monthly statement or does it have to go under seperate cover. For new accounts we are going to put the notice under our terms and charges statement. Also does anyone have any model language that can be used?

Found several notices on the internet sites of other banks. Cobbed together and made our own. We are including it as a statement stuffer.

We are doing a statement message for existing commercial accounts and adding a disclosure to our new account kit for new customers.

Are any banks out there doing anything on the loan side for Reg GG?

bump

Our loan customers get CIPd just like our deposit customers, so the Reg GG Certification is part of our CIP process.

Likewise here - they get the MSB and Reg GG questions when the relationship is opened. That is documented on our CIP information as well as on our computer system for tracking purposes. We then pull a twice per month report on that info along with other CIP missing information for monitoring/cleanup purposes. given the 12/1/09 implementation date of this, we sent out our notice in November 2009, and began tracking this at that time.

To avoid the muddy route of tracking transactions and blocking, as a bank you could make the decision to not do business with any business which conducts any type of internet gambling and have the customer sign a statement acknowledging this.