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BankersOnline.com Forums Banker Forums Operations Compliance wire tranfers/policy and procedures
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#1745057 - 09/27/12 10:25 PM wire tranfers/policy and procedures
ackcompliance Offline
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Joined: Nov 2009
Posts: 139
Is it mandatory to have written policies and procedures for wires?

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Operations Compliance
#1745064 - 09/27/12 10:48 PM Re: wire tranfers/policy and procedures ackcompliance
ackcompliance Offline
100 Club
Joined: Nov 2009
Posts: 139
We are a small bank and we have procedures in place but nothing written down.

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#1745088 - 09/28/12 03:02 AM Re: wire tranfers/policy and procedures ackcompliance
Greg Offline
Platinum Poster
Joined: May 2004
Posts: 833
Michigan
If you don't have written procedures how do you discipline an employee for violating them?
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If you approach life with pure logic you can avoid almost all of the fun.

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#1745102 - 09/28/12 12:29 PM Re: wire tranfers/policy and procedures ackcompliance
Retired DQ Offline
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Retired DQ
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
I am a firm believer in written P&P.
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Get your facts first, then you can distort them as you please. - Mark Twain

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#1745154 - 09/28/12 02:32 PM Re: wire tranfers/policy and procedures ackcompliance
ackcompliance Offline
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Joined: Nov 2009
Posts: 139
Yes I think we need them too and I don't know how not having a written wire policy would have slipped through the cracks for that long...

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#1745155 - 09/28/12 02:35 PM Re: wire tranfers/policy and procedures ackcompliance
HappyGilmore Offline
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Joined: Jun 2004
Posts: 19,855
Pulling people out of the ditc...
what do you provide to auditors or regulators when they ask "please provide a copy of your wire policy and procedures?"
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#1745242 - 09/28/12 04:27 PM Re: wire tranfers/policy and procedures ackcompliance
ackcompliance Offline
100 Club
Joined: Nov 2009
Posts: 139
I don't know what they did in the past... The BSA policy has a little blurp and the ACH policy has a little information in it as well but as for procedures nothing is written down. I'm assuming everything was done through interviews in the past.

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