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.

However he/she is still a customer. I would log as a customer.

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.

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.

There is no mud. It's just the way the rule was written. Loan accounts don't count; deposit accounts do.

So if they were merely a loan customer, you treat them as a Non-Customer for purposes of MI logs?

Yes, that is correct. Perhaps a better term is a "non depositor."

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.