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#1776783 - 01/16/13 03:24 PM BSA Exam
lds1958 Offline
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Joined: Oct 2006
Posts: 508
We have an FDIC Examiner that is saying we have to complete a written risk assessment for EACH new consumer account that we open. We asked for the book and page that says we have to do that and she is referring us to page 63 of the exam manual. We CIP all our new customers and we have completed a risk assessment for our products which include consumer accounts and we have rated them as LOW risk customers. We monitor all cash that is deposited into accounts on a daily basis as well as other reports (kiting and such). We complete a High Risk assessment on each one of our business customers however she is not satisfied with that.

Please help!!

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#1776790 - 01/16/13 03:28 PM Re: BSA Exam lds1958
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,285
Some banks deal with this by adding questions to their account opening process that will identify individual customers who will present higher risk, such as PEPs, possibly NRAs, and so forth.

Anyone who does not trigger those identified categories is low risk until something in the future might trigger a rating increase.
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy

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#1776940 - 01/16/13 07:27 PM Re: BSA Exam lds1958
MagicCity Offline

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Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
Not to discourage you further, but they will never be satisfied with your process.
Whatever it is you do, and no matter how adequate it is, they will say you should be doing that much more.
That is the reality of BSA.
If you don't have the questions that Kathleen suggests on your application, then add those and it should be sufficient for the time being.
Good luck.

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#1777173 - 01/17/13 12:40 PM Re: BSA Exam lds1958
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
We have an FDIC Examiner that is saying we have to complete a written risk assessment for EACH new consumer account that we open.

Your examiner has no real comprehension of what it is she is doing. There have been a number of threads here that discuss the fact that doing AML risk assessment on consumer accounts is a waste of resources; it is the antithesis of risk based decision making. Tell her you disagree, but if it appears in the written report you will investigate your options.

As suggested, you do need to ask about citizenship. You do need to ask about possible connections to the government of a foreign county. Those queries are implicit in your need to identify customers "subject to expanded examination overview."
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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#1777174 - 01/17/13 12:57 PM Re: BSA Exam lds1958
rlcarey Online
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Joined: Jul 2001
Posts: 79,959
Galveston, TX
You might also want to review Appendix K in the examination manual and maybe show it to her. You will notice that Resident Consumer Customers do not have a requirement for the developement of a unique profile in their example of a bank establishing customer risk versus monitoring systems.
The opinions expressed here should not be construed to be those of my employer:

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