We have recently gotten new software that will allow online applicants to open new accounts. As the BSA compliance officer I was not included in any of the discussions on how this would work. Now management is implementing the program and I am trying to ask questions concerning CIP and CDD. They basically have shut me out from giving an input. They are goint to push forward no matter what I have to say.

Has anyone else had to deal with this? What steps should I take?

Your CIP, OFAC and general BSA risk assessments will need to be updated. Add the new product (account opening process) and request that the necessary information be completed.

If they still will not cooperate, you will have to see if you can go to your audit committee (assuming you have one) or board. If no luck here, at least by sending out the risk assessment requests you are on record as doing the right thing and attempting to get the needed information.

Not uncommon at all. Besides the advice offered by Kathleen, I would document all of your requests for information and that you want to be included in the discussion prior to rolling out the new process.

See, I consider myself lucky then. We'll be rolling this out next year and I was one of the first consulted for input and part of the process. In this day and age, management at Banks need to "get" the importance of involving compliance from the beginning of a project, service or product.

You are lucky!!! VERY lucky.

I know Jenny, I know.

Our examiners in the past few years have been asking us for project management documentation on new products and services to see if Compliance has been involved in the process before it is rolled out. I am not always included at the beginning of the process but generally included at some point in time for my input.