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#2085411 - 06/27/16 07:10 PM NBFI Monitoring
Community Banker Offline
Member
Joined: Nov 2008
Posts: 67
We are a very small community bank. Up until this point we have never banked MSBs nor NBFIs. Management is wanting to begin banking NBFIs. Can someone point me in the right direction to find a checklist that will include all of the points that I will need to monitor as well as the documentation that I need to retrieve from customer? I am trying to determine the time that will be involved in this review process in hopes of creating a service charge that will at least offset some of the time that will have to go into monitoring these types of accounts. Any help you can provide is greatly appreciated.

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#2085423 - 06/27/16 07:23 PM Re: NBFI Monitoring Community Banker
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
Your starting point should be the "Nonbank Financial Institutions - Overview" section of the FFIEC BSA/AML Examination Manual. While you won't find a checklist, you will find guidance as to the risk factors and risk mitigation activities. Since the NBFIs may run the gamut of a little to a lot of risk, it would be hard to determine the time involved until you've got some real cases with which to analyze.
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#2085427 - 06/27/16 07:28 PM Re: NBFI Monitoring Community Banker
Big Dog Offline
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Big Dog
Joined: Mar 2005
Posts: 2,659
Kennel
Agree with Doug. Start with the exam manual. Make sure Sr. Management understands that the exam manual helps outline "minimum" expectations of examiners. Your examiner expectations may vary (meaning could be way higher.)
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#2085432 - 06/27/16 07:35 PM Re: NBFI Monitoring Community Banker
Community Banker Offline
Member
Joined: Nov 2008
Posts: 67
Thank you both for your comments! I will begin there.

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#2085435 - 06/27/16 07:40 PM Re: NBFI Monitoring Community Banker
Daisy Doodle Offline
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Joined: Feb 2014
Posts: 1,030
Southern U.S.
We just had our exam--no criticism on NBFI monitoring--we don't do anything across the board but check their licenses are current. Some of them hit high risk in our BSA software and if they do they get a high risk review, but there are many others who do not hit high risk.

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#2085442 - 06/27/16 07:52 PM Re: NBFI Monitoring Community Banker
Community Banker Offline
Member
Joined: Nov 2008
Posts: 67
Thanks!

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#2085455 - 06/27/16 08:09 PM Re: NBFI Monitoring Community Banker
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Developing a fee schedule to offset the costs of this customer vs. any other would be appropriate.
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#2085531 - 06/28/16 01:22 PM Re: NBFI Monitoring Community Banker
BuckDog Offline
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Joined: Jun 2006
Posts: 123
Tennessee
As stated above, some NBFI are higher risk than others. We start out with a Questionnaire, they have to provide all licenses, if an MSB their registration with FinCen, a site visit and then Management approval who will determine if there is to be an additional fee to offset costs for monitoring. The question asks by the Examiner is "what is your process" and they have been okay with it.

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#2205122 - 02/05/19 07:21 PM Re: NBFI Monitoring BuckDog
KGBanker Offline
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Joined: Feb 2009
Posts: 3
Washington
I know this is a few years ago, but would you be willing to provide a copy of NBFI questions? Do you ask for completion of AML certification from NBFI?

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#2228146 - 01/02/20 04:39 PM Re: NBFI Monitoring Community Banker
Ann Offline
Platinum Poster
Joined: Jul 2001
Posts: 554
South Carolina
Trying to sort out the numerous businesses that might be considered an NBFI. The manual is vague on insurance companies. Do you list all insurance companies as an NBFI just because they issue checks for claims, or just certain ones who may offer banking services?

Thanks for your help!

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