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#187473 - 05/06/04 02:39 PM CIP Exam
Anonymous
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Has anyone had a regulator look at your CIP program? If so, can you share what types of things they are looking for? I know that exam procedures have not yet been issued but that does not seem to stop some of the examiners.

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BSA/AML/CIP/OFAC Forum
#187474 - 05/06/04 02:40 PM Re: CIP Exam
Skittles Offline
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TN
Not yet - but they will next week. I'll post what I find out then.
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#187475 - 05/06/04 08:11 PM Re: CIP Exam
FlBankerGal Offline
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FlBankerGal
Joined: May 2002
Posts: 91
Had state examiners in last week. One "recommendation" that they made was to tighten up on reviewing activity on "high risk" accounts. The other was, for lack of a better word, we should be "profiling" our customers. It's not enough tha we ask the typical questions - how they came to us; what types of transactions will they do; what services do they need - we need to document the responses! Other than that they had no issue with our CIP. Good luck!

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#187476 - 05/06/04 08:19 PM Re: CIP Exam
Elwood P. Dowd Offline
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Elwood P. Dowd
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Next to Harvey
Anon,
If you want some really scary CIP exam narratives, hope that some more state supervised banks from Florida post here. Some of their examiners supplement the CIP's published requirements with some requirements they have dreamed up on their own.
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#187477 - 05/06/04 08:25 PM Re: CIP Exam
Anonymous
Unregistered

We were examined recently, but our bank has gone overboard with CIP. We collect, record, track and image everything.
Examiners told us that we needed to back-off. They did look real close at our policy and procedures, but went no further.
Sorry I couldn't be more help

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#187478 - 05/06/04 08:25 PM Re: CIP Exam
LiL Bit Moore Offline
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LiL Bit Moore
Joined: Nov 2002
Posts: 624
Texas
Anon - Since you didn't specify who your regulator is...FDIC has issued updated BSA/AML Examination Procedures that include USPA and CIP. Here is the link:

FDIC BSA/AML Examination Procedures

Good Luck!
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#187479 - 05/06/04 08:39 PM Re: CIP Exam
JacF Offline

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Joined: Nov 2001
Posts: 6,719
PA
Quote:

We collect, record, track and image everything.
Examiners told us that we needed to back-off.


What practices did they ask you to back off from?

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#187480 - 05/06/04 09:34 PM Re: CIP Exam
skinnyminny Offline
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skinnyminny
Joined: Mar 2002
Posts: 395
Heaven in comparison to my pri...
Had OCC BSA Exam in March. Following CIP areas were covered:

1) Identification procedures-make sure you document the "verification process". Do your practices for CIP match your actual policy?
2) Does your policy address the terms under which you "will not" open an account?
3) High Risk accounts-make sure you have identified these accounts according to your policy guidelines.
4) Monitoring high-risk accounts-have you scheduled a time frame for the review of these accounts? Does your policy match the current practices that you are actually performing?
5) Did you document training on CIP? Is it documented?

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#187481 - 05/07/04 06:15 PM Re: CIP Exam
ACE Offline
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Joined: May 2002
Posts: 103
OTS completed our regulatory exam last week. They stated that our procedure was more than adequate. When I asked if we were going "overboard," the examiner said that he was not at liberty to say what was excessive and what wasn't. We should continue to follow our current procedure. I am simply happy that it was "more than adequate," because Lord knows what would have happened if it was "less than adequate!"
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#187482 - 05/07/04 06:45 PM Re: CIP Exam
DeeQ Offline
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DeeQ
Joined: Dec 2002
Posts: 40,765
Turnpike Exit 10
Here's what the OTS gang is using as supplemental guidance:
RB 18-6
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#187483 - 05/10/04 06:02 PM Re: CIP Exam
Skittles Offline
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Skittles
Joined: Sep 2002
Posts: 13,963
TN
Our exam is currently on-going. The FDIC examiner told me our policy and procedures look good. I know we go overboard and attempted to get some guidance, but she told me that it was up to our institution to set the guidelines.

On a side note, she had a problem with one of my SARs. We knew the individual was structuring (he deposited $8,000 cash on one day and said he'd be in the next day to deposit the remaining $5,000 cash) and we filed a suspicious activity report. She told me that we also should have done a CTR and that there was a special exemption to total the two amounts on different days. That one I have called her on. I'm sure it has to be over $10,000 on one business day, no matter what the circumstances.
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#187484 - 05/10/04 06:26 PM Re: CIP Exam
Elwood P. Dowd Offline
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Joined: Aug 2001
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Next to Harvey
Quote:

That one I have called her on.




Stick to your guns (gently); you are right.
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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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#187485 - 05/10/04 06:32 PM Re: CIP Exam
Cathy P Offline
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Cathy P
Joined: Jan 2003
Posts: 318
NE
We are having a State Safety & Soundness Exam later this month (first look at CIP). I feel confident about our policy, however, some of our documentation (ex. CIP Audit Sheet with required information to be kept for 5 years from opening) is lacking. Would you recommend we go back and make sure all of the sheets are completed properly or just try to do it correctly going forward? (This goes for lending, mortgage and deposit)

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