Really need assistance...We just had regulators leave our institution and they are asking us to revamp our High Risk Customer Visitation Policy because ours is just too vague. Does any one have one that you could share with me?

Thank you....!!!!!!!!!!

The only high risk customers we require a site visit on are our MSB customers. Other than that, we use google map search to verify the business at account opening. If there are questions concerning activity, the account officer is contacted and if he needs to visit the customer to verfy the activity, we will document that in the EDD write up.

We have very few high risk customers so this is not really an issue for us.

You might want to share what your regulators said was "too vague." That way, those who might be willing to make you a gift of their work product would know if theirs is any better.

Our policy would basically states that visits to the business customers' headquarters are good banking practices and that the Account Officer will be responsible to visit the BSA high risk customers. It also states that if a visit is not conducted, the account officer will contact the customer via telephone and document the phone call.

I am not looking for the actual policies...I would just appreciate any assistance as far as what other institutions are doing in reference to visitation of high risk customers.

We visit our cash intensive businesses annually and document as such. It's quite simple and has been sufficient.

I've seen (and agree with) rating systems wherein a customer's numeric score goes up if there has been no on-site visitation in the last 12 months and goes down if there has; e.g. the bank would subtract 2 points if a customer had had a visit and add 2 points if it had not. A net swing of 4 points gives the bank that is trying to manage its number of high risk customers an incentive to visit them.

Oftentimes the "visitor" is required to complete a worksheet to document signage and conversations with employees.

Thank you all for your assistance!!!