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#1392855 - 05/18/10 06:37 PM Requiring employees to open account
inCompliance Offline
New Poster
Joined: May 2010
Posts: 19
Ohio
I would like to get the group's opinion on this. In an effort to ensure that all employees of a certain department (mortgage) are periodically checked against the OFAC SDN list (new Fannie Mae requirement), is it possible to require that each employee open a checking or savings account? All account holders are regularly checked, and this would ensure that employees are as well. There is only a small percentage of employees who don't already have accounts, but I wondered if there is a prohibition on requiring this of an employee. Thoughts?

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#1393006 - 05/18/10 08:14 PM Re: Requiring employees to open account inCompliance
nemsi Offline
Gold Star
Joined: Nov 2005
Posts: 383
I have this same concern and would like to know what others are doing to make sure employees without accounts are checked when the list is updated.

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#1393007 - 05/18/10 08:15 PM Re: Requiring employees to open account inCompliance
JacF Offline

Power Poster
Joined: Nov 2001
Posts: 6,719
PA
Is it possible to create a CIF record without an account for OFAC scrubbing purposes?

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#1393099 - 05/18/10 09:38 PM Re: Requiring employees to open account inCompliance
Deena Offline
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Deena
Joined: Nov 2000
Posts: 2,701
PA
inCompliance, can you provide a link to the new Fannie requirement? I wasn't aware of it.
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Opinions expressed are mine and not necessarily those of my employer.

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#1393192 - 05/19/10 01:26 PM Re: Requiring employees to open account inCompliance
inCompliance Offline
New Poster
Joined: May 2010
Posts: 19
Ohio
inCompliance, can you provide a link to the new Fannie requirement? I wasn't aware of it.

Thanks to all for your feedback. I have since been provided with more information and Fannie's new requirement is different than originally thought. It is coming from the Loan Quality Initiative. One of the pieces that will become effective in June is the requirement to validate qualified parties against the GSA list and HUD's LDP list. So to clarify, they are not asking for the OFAC list to be checked. They're leaving that to the Patriot Act. However, this is not an easy requirement because we will need to run the names of our staff through the LDP and GSA lists. At least with OFAC, we have that check in place for other requirements and we could piggyback an existing process. Unfortunately, this is another new process... The link to Fannie's Loan Quality Initiative page: https://www.efanniemae.com/sf/lqi/index.jsp

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#1393351 - 05/19/10 03:38 PM Re: Requiring employees to open account inCompliance
Deena Offline
Power Poster
Deena
Joined: Nov 2000
Posts: 2,701
PA
Thanks very much for the information.
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Opinions expressed are mine and not necessarily those of my employer.

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#1394087 - 05/20/10 05:17 PM Re: Requiring employees to open account Deena
Georgia Plum
Unregistered

I thought this was already a requirement.

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#1394542 - 05/21/10 02:49 PM Re: Requiring employees to open account
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Some teller systems have the ability to create a name/address file record that will be subject to OFAC scanning nightly. If you are involved with any aspect of managing your CTR process, you need to get very well acquainted with your teller system. Don't rely on current teller process - identify system capabilities.
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