The OCC was pretty specific on doing due diligence and enhanced due diligence on all new NGOs. We also had to go back and review our exisitng NGOs to make sure none were high risk. We've added a line to our Risk-rating profile for new accounts and made up a NGO profile form for any high risk NGOs using the bullet points from the FFIEC Manual. (page 320-321 in the Red Book.)
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