Hi, As a former OTS shop, I am working on the MLR (money laundering risk assessment) for the OCC.
My question is, if you have IAT countries (cross border ACHes) with less than 1 txn per day and less than $1000 per day, how do you list it on the MLR?
As 1 and 1?

TIA!

Just getting into it, too, but I believe in the webinar they said to round everything up. So, I think 1 and 1.

Yes.

This is my 6th year submitting it. Let me know if you have any more questions.

The same goes for your wires if they are small like that too.

Thanks, I appreciate the input.

uh! MLR report.... my last bank was OCC and I was in charge of that report. No fun!

Thanks a lot...

Here's a better answer than my previous attempt.

On page 8 of the user guide, it says to round everything up.

Thanks, that is what I have done. It is not so bad once you start working on it. It looks more overwhelming than it is.

You are correct, and in some cases this grossly overstates your volume as they are looking for average daily amounts and average daily volumes. Answering 1 and 1 looks like you do 1 per day for $1,000 when you may have had a handfull or less for the year for one amount. Been there, done that.

Switching gears....We have a dubious set of used car dealers, who combined have a net negative balance (as of Sep 30)! I am inclined to put zero, but I'll bet the software forces me to put a "1". Opinions on what to do?

Cornhusker- Yes, you should put a 1 for the dollar amount. It won't let you put a 0 if you put an actual number in the # of accounts field.

Get rid of them before the report is due?

Wow a -$9000 balance gets reported as $1,000. That's rounding! thanks Froggy.

Question about #49 on the MLR "Seller of Prepaid Access" How do you report on this? Every convenience store, restaurant, retail, grocery and fast food joint sells some form of these cards. Any guidance on filling out that area of the MLR will be greatly appreciated!