I'm out at Appendix K of the BSA exam manual. For low risk customers (Identified in the example chart as resident consumer DDA, Savings, etc) a "basic profile, generic threshold monitoring" is the suggestion. Can someone enlighten this non-BSA officer about the "basic profile?"

Thanks.

Purpose of account, expected activity, employment information.

Perfect! Thanks.

I was at an industry conference earlier this year and when the question was asked as to how many people actually use that information after it's collected, only about 1/3 of the 600+ people in the room raised their hand.

I'm curious as to whether anyone has removed "expected activity" dollar ranges from their new business account questionnaire. If so, did you receive any pushback from the examiners? We're thinking of removing the dollar ranges, but leaving the types of activity.

We collect the expected activity with ranges, employment and purpose of the account. I only use the ranges if the account was flagged by the AML system for some reason. I don't find the ranges helpful at al but I don't plan on eliminating it. I want the personal bankers to continue to have some conversation with the customers. The type of activity is very helpful- yes.

Thanks Lilly!

In discussing this with a couple other peers, our feeling is that if someone is planning on doing anything shady, they're going to tell us the ranges that fit the shady activity, so what use is it really?

I'd love to hear from others.

Those conversations should happen regardless of any type of BSA/AML motivation. Without knowing the answers to those questions, how can anyone possibly recommend the best product or products for the customer and increase the ability to cross sell additional products and services?? What you do is teach your new accounts people to cross sell efficiently and then it just comes down to documenting what they found out.

I can't tell you how many times I am in banks where the new account person leads off with, I have to ask you these questions to comply with government regulations. I just sit there and think to myself, wow, really??

I didn't know we hired you as a consultant Randy. If you were to ask anyone here what "cross sell" was they would probably think it was a new type of crossword puzzle (since we hand those out to the tellers to do daily).

I'd rather have the issue of them not knowing what cross-selling is that my current struggle of compliance training being pushed back for new staff so they can get more sales training in their first 30 days

I haven't taken a look at the CDD stuff that came out from FinCEN yesterday. Hard to find time for reading about potential future proposed rules though!

FinCEN's latest offering is a couple of documents to supplement its August 4, 2014, proposal to enhance customer due diligence requirements. Apparently several banks commented on the proposal, asserting that it would be more expensive to implement than FinCEN had estimated/guessed. After FinCEN reached out to those banks for more info, it decided the impact might be greater than the threshold amount requiring additional information on cost of implementation, so FinCEN is now supplying that information.

And it is again available for comment, as it is probably woefully underestimated, although I have not reviewed in detail.