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#2033145 - 08/12/15 01:59 PM Lookback period for structuring
Daisy Doodle Offline
Diamond Poster
Joined: Feb 2014
Posts: 1,030
Southern U.S.
Last bank where I was BSA Officer the look-back period was 2 weeks and we never received any criticism on that. Here is it 4 weeks. I questioned our account rep at BAM about this because of the number of alerts and was told the most common look-back periods in use by their customers were 1 week or 4 weeks. Neither seems good to me--one is too short and one seems long to me. Can others comment on their look-back periods and any examiner input they have received?

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#2033249 - 08/12/15 04:04 PM Re: Lookback period for structuring Daisy Doodle
mdog76 Offline
Platinum Poster
Joined: Jan 2007
Posts: 645
We use Yellowhammer and we have our look-back set for 2,5,7 and 10 day structuring. We just had a BSA exam and asked the examiner what was an appropriate look-back for structuring and said "There is no right or wrong answer". She wouldn't commit to an answer while questioning transactions one or even two months apart.

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#2033296 - 08/12/15 05:54 PM Re: Lookback period for structuring Daisy Doodle
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Quote:
"There is no right or wrong answer".


If you want a basis for your decision compare what you got with 4 weeks to what you got with 2 weeks. My guess is the extra time isn't going to show you that much extra activity.
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