The current procedure for commercial loan customers, is to have them complete a risk profile. One of the questions on the profile is asking the customer if they own Privately Owned ATM"s. The risk profile was created by the previous BSA Officer, with the instructions that a risk profile should be completed on the business and on each signer of the loan. While I don't disagree that the risk profile should be completed for each signer and the business, I disagree with her instruction that it is necessary for the customers to be asked if they have Privately Owned ATM's. The title company, that is closing some of our loans says that we are the only bank asking customers to answer that question. Drilling down on CDD and Privately Owned ATM's,has more reference to deposit accounts and Privately Owned ATM.