Looking to get some insight regarding the monitoring and level of due diligence associated with "property management" companies as well as consumer customers that deposit rental income.
It sort of dawned on me today that we have some customers in the property management industry, however we don't have information regarding how many properties they own, locations, etc., which I would consider to be quite the flaw as far as CDD/EDD is concerned. We also have consumer customers who from time to time deposit a mix of cash/checks (containing "rent" on the memo line), and again, no supporting documentation that says how many properties owned, locations, etc. In a perfect world I'd love to have all that information, however I'm assuming that as with anything I request there can and will be kickback, so I was looking to cite the examples of some other FI's and what their practices are, or some examiner comments that some have received in regards to this. I'm just thinking how easy it could be to say "yeah, I own some properties, but they're in low income areas so I collect cash because I don't trust the tenants", without actually owning any property as a nice little ML scheme. I understand that without obtaining actual documentation of the ownership of the properties it would still be speculative, but at least a number of properties and MAYBE a location would allow for enhanced monitoring of these customers.
Any input is much appreciated!
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