We are in the middle of an examination and the Examiner is asking if the BSA Department received 314(b) training since we recently just became a 314(b) bank. Does anyone know of a webinar that focus on 314(b)or has procedures in place for this specific area? Thank you.

We have procedures, but I have not heard of any formal training available other than what banks developed themselves. With writing your procedures, you need to think about what your standards will be (how to facilitate the request, what you will ask for, how you will verify and document validation that the recipient bank is a participant as well as the flip side of receiving them - same things....)where to document 314b requests, QA'ing that they were done correctly, standards on using 314b information in investigations and/or SAR narratives. As you start building the process, you'll think of the other rules you need to set but I would begin with those. Good luck!

Ask the examiner to cite where the "requirement" for 314b training is. IMO as long as your procedures are proper he should have no basis for comment.

You must have a good BSA program Calmeida!
Between your examiners comments on financial statements and this one, - I think they cannot find anything to write-up and are reaching

The statute and regulation mostly focus on the grant of permission and would not take too much time to cover. FIN-2009-G002 expands the scope of information sharing far beyond what a focused reading of the statute and regulation suggest and it would be a challenge to explain to most audiences.

Otherwise, I would guess that 30 - 45 minutes of a one hour session would be devoted to your internal procedures.

P.S. The recommendation is appropriate. If it's included in the written report that's a somewhat rude response to a bank that is actually trying to follow its regulator's encouragements to register.

Does anyone have a tracking log for 314(b) requests that they would like to share? Thank you.

PM me your address.

P*Q,

Do you mind contributing your 314(b) tracking log to the BOL Tools sections?

THANKS!