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#1763617 - 12/04/12 04:05 PM
OCC MLR Questions
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10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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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!
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Get your facts first, then you can distort them as you please. - Mark Twain
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#1763635 - 12/04/12 04:20 PM
Re: OCC MLR Questions
Retired DQ
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Platinum Poster
Joined: Feb 2010
Posts: 960
Illinois
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Just getting into it, too, but I believe in the webinar they said to round everything up. So, I think 1 and 1.
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I thought getting old would take longer.
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#1764042 - 12/05/12 04:22 PM
Re: OCC MLR Questions
Retired DQ
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Gold Star
Joined: Mar 2012
Posts: 305
Spartan Country!
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uh! MLR report.... my last bank was OCC and I was in charge of that report. No fun!
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Everyone should believe in something. I believe I will head for the beach!
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#1764446 - 12/06/12 02:26 PM
Re: OCC MLR Questions
Retired DQ
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Platinum Poster
Joined: Feb 2010
Posts: 960
Illinois
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Here's a better answer than my previous attempt.
On page 8 of the user guide, it says to round everything up.
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I thought getting old would take longer.
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#1764697 - 12/06/12 06:50 PM
Re: OCC MLR Questions
Retired DQ
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Member
Joined: May 2007
Posts: 83
Texas
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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! 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.
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#1764816 - 12/06/12 08:21 PM
Re: OCC MLR Questions
Retired DQ
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100 Club
Joined: Mar 2009
Posts: 133
flyover country
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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.
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It is actually possible for you and I to have different opinions and yet still live peaceably upon this planet.
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