I would like to know what information FI's are obtaining from high risk customers at account opening as to anticipated activity. In addition to determining what types of transactions, such as wires, currency deposits and withdrawals, etc, are you also obtaining anticipated dollar amounts in each of these activities? Or, do you just ask whether they will be having these types of transactions?
I know it's difficult for new businesses to guess at volumes.
I'm interested in exactly what information you are requesting, and whether examiners have been happy with it.

Thank you for your help!

So far, we've had no issues with our regulators. For all businesses, we ask the Anticipated % of transactions first from the credit side and then from the debit side ---- How much of your deposits will be cash, checks, ACH, POS, Wires, etc? Then, how much of your debits will be for cash withdrawals, checks, ACH, POS, or Wires? The anticipated percentages must balance to 100%. Businesses may not know how much in dollars to expect, but they know whether they plan on accepting cash, debit cards, etc.

For consumers, we ask the same questions, but only if the input in the other fields calculates to make them High Risk. Otherwise, we simply question which banking services they plan on using -- monetary instruments, wires, internet banking, bill pay, etc.

Hope that helps.