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#1462747 - 11/02/10 07:59 PM
Wire log information
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100 Club
Joined: Jan 2009
Posts: 106
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What information is required to be kept on a wire log?
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#1462828 - 11/02/10 08:58 PM
Re: Wire log information
TMichelle
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Joined: Aug 2001
Posts: 21,939
Next to Harvey
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You are not required to have a wire log as such, so there are no explicit requirements. Bank record retention requirements for wire transfers begin at 31 CFR 103.33(e).
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#1462864 - 11/02/10 09:25 PM
Re: Wire log information
Elwood P. Dowd
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100 Club
Joined: Jan 2009
Posts: 106
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ok, let me put it this way ... what information if any are other banks keeping on a wire log? (If you do not have an automated BSA AML system how would you check 314 request without a log?)
When it (31 CFR 103.33) request you keep the identity of the beneficiary's bank, does that just mean the name of the bank or would it include some sort of address or location for the bank also?
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#1462987 - 11/03/10 01:22 PM
Re: Wire log information
NotDoneYet
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100 Club
Joined: Jul 2006
Posts: 183
Below the Mason Dixon Line
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We have automated BSA/AML software that is monitored on a monthly basis. However, our auditors/examiners still require us to keep spreadsheets. The wire department e-mails daily and I copy the info into an excel spreadsheet. I have a separate spreadsheet for incoming and outgoing wires (domestic and international) with the following info-------Wire Date, Originator, Beneficiary, Adjacent Bank, Bank Location, Payment Method, Account Number, Wire Amount, Fee. I also have a "Comments" column.
Last edited by elvisfan; 11/03/10 01:24 PM.
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#1468857 - 11/17/10 03:28 PM
Re: Wire log information
Lilly C
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100 Club
Joined: Jan 2009
Posts: 106
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Thanks everyone! We currently have a log that list originator, ssn/tin, acct number, amount, beneficary, bene bank, and country if foreign. Some employees want to stop using the log and go to using system generated reports that only show originator name and address, beneficary name and address (which a lot of time list the bank instead of actual beneficary) and amount. We do not do wires for non customers. We keep all the information on the actual wire request (paper) so they want to stop having to key the information into a seperate spreedsheet "log". I'm just thinking the examiners will not be impressed by this. Any thoughts?
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#1468931 - 11/17/10 03:57 PM
Re: Wire log information
TMichelle
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Joined: Oct 2000
Posts: 40,086
Cape Cod
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Any time you abandon digital methods for keeping these records in favor of paper reports or paper wire requests you lose the ability to "slice and dice" the data, sort it and otherwise massage it to help make it more meaningful. Sure, it's a PITA to key those data into the spreadsheet each day, but it's a heck of a lot easier to do it daily than to try to attack it on a quarterly or less frequent basis.
If you use the Fed for wires, check with your Fed contact to see if there is an option available to map all your incoming and outgoing wire data into a spreadsheet automatically.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1471135 - 11/22/10 05:26 PM
Re: Wire log information
John Burnett
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Joined: Jan 2009
Posts: 106
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We do not have Fedwire we use a correspondent bank and the log that generates from their system has limited information. It list the orignator and beneficary and both of their addresses and the date and amount. It does not give an account number, ssn/tin or the other bank's info/location etc. With the travel rule aren't we required to keep this information also? And if yes, does it need to be in the log or can we say "we keep it" by tracing it back to the original paper documents? (i want to keep the log, just preparing myself for their arguments)
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#1471160 - 11/22/10 05:55 PM
Re: Wire log information
TMichelle
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Joined: Oct 2000
Posts: 40,086
Cape Cod
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You can maintain the information in any form you wish, as long as it includes what's required. As for retrievability (this is your key), if you are the sending bank you have to be able to retrieve the info by sender's name and, if the sender is a customer, that account number. If you are the beneficiary's bank, you have to be able to retrieve it by the beneficiary's name and, if a customer, by account number. [31 CFR 103.33(e)(4).
If the data are all in electronic form indexed to name and account number, retrievability seems a no-brainer. If detail is found only in the original paper documents, your retrievability is only as good as your paper filing skills and depends on every piece of that record being returned to the proper place if removed.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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