Thread Options Tools
#1381686 - 04/26/10 08:48 PM any improvements to GG?
Trees Offline
Power Poster
Joined: Apr 2005
Posts: 4,013
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.

Return to Top
General Discussion
#1381822 - 04/27/10 12:53 PM Re: any improvements to GG? Trees
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,000
Cape Cod
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.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1381887 - 04/27/10 02:21 PM Re: any improvements to GG? John Burnett
Trees Offline
Power Poster
Joined: Apr 2005
Posts: 4,013
Great!

Return to Top
#1382027 - 04/27/10 03:44 PM Re: any improvements to GG? Trees
Soccer Offline
Platinum Poster
Joined: Jan 2010
Posts: 995
Utopia
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?
_________________________
Everything happens for a reason

Return to Top
#1382247 - 04/27/10 06:30 PM Re: any improvements to GG? Soccer
Trees Offline
Power Poster
Joined: Apr 2005
Posts: 4,013
Found several notices on the internet sites of other banks. Cobbed together and made our own. We are including it as a statement stuffer.

Return to Top
#1384988 - 05/03/10 05:28 PM Re: any improvements to GG? Trees
Brad B Offline
100 Club
Brad B
Joined: Apr 2002
Posts: 213
KS
We are doing a statement message for existing commercial accounts and adding a disclosure to our new account kit for new customers.
_________________________
"Sarchasm" is the gulf between the author of sarcastic wit and the person who doesn't get it

Return to Top
#1385156 - 05/03/10 08:19 PM Re: any improvements to GG? Brad B
JobSecurity Offline
Platinum Poster
Joined: Oct 2009
Posts: 536
Are any banks out there doing anything on the loan side for Reg GG?

Return to Top
#1393802 - 05/20/10 01:18 PM Re: any improvements to GG? JobSecurity
JobSecurity Offline
Platinum Poster
Joined: Oct 2009
Posts: 536
bump

Return to Top
#1394122 - 05/20/10 05:44 PM Re: any improvements to GG? JobSecurity
Georgia Plum
Unregistered

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

Return to Top
#1394375 - 05/20/10 11:15 PM Re: any improvements to GG?
Moman Offline
Platinum Poster
Joined: Jul 2004
Posts: 505
WA
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.

Return to Top
#1394845 - 05/21/10 08:03 PM Re: any improvements to GG? Moman
Bob The Banker Offline
Platinum Poster
Bob The Banker
Joined: May 2010
Posts: 958
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.

Return to Top