Thread Options
#1763746 - 12/04/12 06:58 PM "Deposit" Customer & MI Logs versus Loan Customer
CantBeShocked Offline
Gold Star
Joined: Apr 2006
Posts: 260
MS
If you have a customer who is ONLY a loan customer, do you enter him/her on the MI log as a customer or non-customer - keep in mind that you have all of his information in your CI system (name, ID, SSN, address, DOB).

A loan customer is not a deposit customer so.............

Thanks.
_________________________
]

Return to Top
BSA/AML/CIP/OFAC Forum
#1763750 - 12/04/12 07:05 PM Re: "Deposit" Customer & MI Logs versus Loan Customer CantBeShocked
Skittles Online
10K Club
Skittles
Joined: Sep 2002
Posts: 13,963
TN
However he/she is still a customer. I would log as a customer.
_________________________
My Opinions Only

Return to Top
#1763759 - 12/04/12 07:09 PM Re: "Deposit" Customer & MI Logs versus Loan Customer CantBeShocked
Doug Hendrickson Offline
Power Poster
Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
I thought the MI portion of BSA/AML talks about an "accountholder", not a customer. A person maintaining a loan is not an "accountholder" for MI purposes, threfore you would record them as a non-accountholder and collect/maintain the appropriate information.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

Return to Top
#1763776 - 12/04/12 07:25 PM Re: "Deposit" Customer & MI Logs versus Loan Customer CantBeShocked
CantBeShocked Offline
Gold Star
Joined: Apr 2006
Posts: 260
MS
Look at page 107 in the FFIEC exam manual. In bold it says, "has a deposit account". That is what is muddying the water - so to speak.
_________________________
]

Return to Top
#1763788 - 12/04/12 07:49 PM Re: "Deposit" Customer & MI Logs versus Loan Customer CantBeShocked
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,629
Cape Cod
There is no mud. It's just the way the rule was written. Loan accounts don't count; deposit accounts do.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1763797 - 12/04/12 08:20 PM Re: "Deposit" Customer & MI Logs versus Loan Customer CantBeShocked
CantBeShocked Offline
Gold Star
Joined: Apr 2006
Posts: 260
MS
So if they were merely a loan customer, you treat them as a Non-Customer for purposes of MI logs?
_________________________
]

Return to Top
#1763803 - 12/04/12 08:30 PM Re: "Deposit" Customer & MI Logs versus Loan Customer CantBeShocked
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,629
Cape Cod
Yes, that is correct. Perhaps a better term is a "non depositor."
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1763848 - 12/04/12 09:55 PM Re: "Deposit" Customer & MI Logs versus Loan Customer CantBeShocked
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,293
Galveston, TX
The other area banks get tripped on is failing to realize that authorized signers, trustees, etc., are also not "accountholders". Any reference to customer verses non-customer needs to removed from any procedures covering these recordkeeping requirements.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z