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#1993449 - 02/04/15 07:30 PM Credit counseling customer
Calmeida12 Offline
100 Club
Joined: Sep 2012
Posts: 249
One of our branches has a prospect customer that is a credit counseling and consolidation of debt business (they use ACH to collect payments from their clients and then make payments to those clients' creditors). From a BSA perspective, what due diligence should we be doing prior to letting this customer open the account? Can anyone think of any red flags or questions to ask ahead of time. Thank you.

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#1993490 - 02/04/15 08:36 PM Re: Credit counseling customer Calmeida12
kw004h Offline
100 Club
Joined: Nov 2009
Posts: 219
Chicagoland, IL
This field is rife with scam artists. Do they charge up front fees? Do they actually provide counseling, or simply provide "informational materials" and then charge the customer exorbitant monthly fees? Does the service they advertise match what is actually provided? Have there been BBB complaints? Also, based on the activity you describe, this customer fits the description of third party payment processor, so consult the FFIEC manual. What is their rate of returned ACH items? Do customers allege the funds were taken without authorizations?

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#1993562 - 02/04/15 10:20 PM Re: Credit counseling customer Calmeida12
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Good suggestions all. Find out why they are leaving their current bank and ask who their contact was there. The contact would probably not be willing to talk to you, but the question is to see how the potential customer reacts to the request. If he doesn't like it, you gotta wonder if leaving was his decision or the bank's.
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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