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#1757497 - 11/13/12 06:39 PM A question of "Risk"
Polo Offline
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Polo
Joined: Feb 2003
Posts: 178
Certainly not to the exclusion of any other component, would you agree that CASH transactions (for most community banks) should be at the top of the Risk level and subsequent monitoring of cash transactions should be first and foremost.
{Again, as applicable to a community banks typical banking activities and not to the diminishment or exclusion of other component, such as foreign, wire, ACH, etc… non-cash transactions.}

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#1757500 - 11/13/12 06:43 PM Re: A question of "Risk" Polo
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
I think it will depend on volume and the number of cash intensives. For instance, we're a small bank and have only a handful of cash intensives. We have a significantly higher volume of ACH transactions than cash transactions, so for us, ACH is higher risk and requires more controls and monitoring. That's not to say we don't monitor cash on a daiy basis, but our cash volume is so low that I spend little time delving into the cash reports. Most of my cash reports are the "regulars" (my handful of cash intensives) and a few odd-balls every now and again. I look more at the odd balls and my ACH transactions.
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#1757501 - 11/13/12 06:44 PM Re: A question of "Risk" Polo
BFrame Offline
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BFrame
Joined: Nov 2011
Posts: 402
USA
When I was at the "big bank" and we had internal auditors show up for their surprise audit, cash handling, cash reporting, cash monitoring, cash security were all on the top of the list.

"Other than the employees, the money is the next most valuable, most at-risk item in the bank." That's what they said. smile
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#1757510 - 11/13/12 06:53 PM Re: A question of "Risk" Polo
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Cash is what is easiest and, thus, what most third party reviewers will focus on. However, I could not say that it's the most important in any bank.
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#1757523 - 11/13/12 07:17 PM Re: A question of "Risk" Polo
Polo Offline
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Polo
Joined: Feb 2003
Posts: 178
I realize that it’s relative and based on the bank’s operations, services, products and situation similar to “Dani’s” response. However “ItsOK” hit the nail on the head. Whether I can say cash transaction are lower risk and ACH or Wire transfers are our biggest risk due to volume, etc… would be my defense if I were in Dani's situation.
However, we are very cash intensive and have a lot of cash intensive customers. With that said, we also have a large volume of ACH and Wire activity. We made the determination that cash is our primary focus because of the anonymity it can provide and the increased possibility of the lack of a paper trail.
We DO monitor Wire, ACH, etc… but devote more effort to our Cash activities because of the above mentioned and we recently were criticized by an examiner for doing so.
We have been doing this for over 10 years and have never had such a criticism. Do you think this may be an isolated opinion or is there a new focus that we were obviously unaware of?

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#1757530 - 11/13/12 07:25 PM Re: A question of "Risk" Polo
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
I think your current examiner is smarter than your previous examiners. The next one may not be. grin
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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