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#2002203 - 03/17/15 08:54 PM Debt Collections for Tokyo Company = TPPP???
CantBeShocked Offline
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Joined: Apr 2006
Posts: 260
MS
Good Afternoon,
We have TPPP customers (approx 5-6) who initiate ACH files through our bank and we have good documentation & EDD reviews on them. Now, we have a potential customer who contacted us today explaining that he needs business banking services for his new company - which is collecting unpaid debts. He is not new to the area, is known by bank personnel and has done this type of work previously - although he has never had banking services with us.

He will be collecting unpaid debts from businesses inside and outside the US, then wiring the payments to the company who is hiring him - a well known tire / rubber company in Tokyo.

Technically he will be a TPPP, although he is not moving funds via ACH.

What documentation do we need to obtain from him? I am asking for copies of his agreement with this company and have asked him to document and explain how he will be receiving payments whether by check or ACH. I have also instructed the branch to explain that we will be reviewing his activity on at least a quarterly basis and will periodically have to ask him for updated information.

Any further input will be appreciated and also, am I correct that he is a TPPP - he just has only one client.

Thanks.!
Last edited by CantBeShocked; 03/17/15 09:06 PM.
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#2002206 - 03/17/15 09:07 PM Re: TPPP - help needed CantBeShocked
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 3,959
New York City
Maybe I'm not understanding this. Why would a tire/rubber company domiciled in Tokyo be funding a debt collector in the US?
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#2002210 - 03/17/15 09:17 PM Re: TPPP - help needed CantBeShocked
BrianC Offline
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Joined: Nov 2004
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Illinois
Can you say money mule?

I knew you could...
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#2002218 - 03/17/15 09:59 PM Re: TPPP - help needed CantBeShocked
CantBeShocked Offline
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Joined: Apr 2006
Posts: 260
MS
Exactly my thoughts. Why would they hire someone on the other side of the world to collect business debts? If they are that large - and the legit company truly is large - surely they have someone on staff (more than one employee) who collects debt.

Thanks guys !
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#2123014 - 03/22/17 03:18 AM Re: Debt Collections for Tokyo Company = TPPP??? CantBeShocked
NBT Offline
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Joined: Feb 2017
Posts: 11
Know this is an old post but what did you do with this customer? We are trying to onboard a similar customer but they perform collections for many large retailers. Trying to determine what to collect before opening account. Thank you!

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#2123015 - 03/22/17 09:13 AM Re: Debt Collections for Tokyo Company = TPPP??? NBT
Elwood P. Dowd Offline
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Joined: Aug 2001
Posts: 21,939
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The most recent official guidance from the FDIC is FIL 41-2014. . It attempts to mask the stink the FDIC put on TPPP's in the past, but still links the previous guidance.

You have exhumed two old threads on the same subject where no real answer was offered. It seems likely that no one in this limited audience makes it a practice to bank TPPP's. If you are thinking about banking a customer that could fairly be labeled as inherently high risk, but have no idea where to start, that's probably the most reliable indicator that you shouldn't do it.
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#2123076 - 03/22/17 03:11 PM Re: Debt Collections for Tokyo Company = TPPP??? CantBeShocked
NBT Offline
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Joined: Feb 2017
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We already bank some TPPPs that are payroll processors but they were all inherited from bank acquisitions. The new potential customer is a debt collector.

Thank you for the guidance!

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