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#2094125 - 08/18/16 09:32 PM Anyone have RDC function overseen by BSA officer
Cher Offline
Member
Joined: Oct 2003
Posts: 98
Florida, USA
Does anyone have the RDC underwriting and annual review function report to the BSA officer? We're considering some reorganization and was wondering how other community banks have the RDC responsibilities broken out. Thanks for any input.

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#2094154 - 08/19/16 02:55 AM Re: Anyone have RDC function overseen by BSA officer Cher
rlcarey Offline
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Joined: Jul 2001
Posts: 79,293
Galveston, TX
Unless you have a BSA Officer that is skilled in credit underwriting, why would it even be suggested??
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#2094170 - 08/19/16 12:54 PM Re: Anyone have RDC function overseen by BSA officer Cher
banker1976 Offline
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Joined: Nov 2005
Posts: 344
Mid-Atlantic
We have an Electronic Banking Coordinator that oversees RDC functions; underwriting part is reviewed by senior lending. These positions report to a Chief Risk Officer. BSA is part of the review process on new RDC customers, and BSA also does a review of a sample selection of existing RDC customers from a BSA perspective on an annual basis.
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#2094185 - 08/19/16 01:42 PM Re: Anyone have RDC function overseen by BSA officer Cher
Beachbum, CRCM Offline
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Joined: Dec 2006
Posts: 482
Knee Deep in Regs
Our Deposit Operations Officer oversees the RDC functions. New RDC customers are underwritten by the Senior Branch Administrator (who is also a senior lender) as part of the overall customer analysis.
like banker1976-
" BSA also does a review of a sample selection of existing RDC customers from a BSA perspective on an annual basis."
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#2094186 - 08/19/16 01:45 PM Re: Anyone have RDC function overseen by BSA officer Cher
Daisy Doodle Offline
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Joined: Feb 2014
Posts: 1,030
Southern U.S.
RDC in our bank is overseen jointly by Credit and Treasury Management.

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#2094200 - 08/19/16 02:15 PM Re: Anyone have RDC function overseen by BSA officer Cher
osucpa Offline
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Joined: May 2011
Posts: 1,400
Handled in our Treasury Services area.

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#2094204 - 08/19/16 02:21 PM Re: Anyone have RDC function overseen by BSA officer Cher
Lilly C Offline
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Joined: Dec 2004
Posts: 209
Sunny Florida
Underwriting is completed by the Treasury Department. In the BSA Department I do a review once a year after the underwriting is completed on the anniversary month. I don't review the underwriting, I just confirmed that is was completed and then I do a BSA annual review. I also don't do it on every RDC customer. BSA reviews are risk assessed and I decide based on the assessment how often I will do the BSA review. BSA review consists of looking for red flags and suspicious activity. It has nothing to do with the underwriting. I document the RDC BSA reviews for audits.

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#2094205 - 08/19/16 02:22 PM Re: Anyone have RDC function overseen by BSA officer Cher
edAudit Offline
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edAudit
Joined: Jul 2008
Posts: 4,772
You are here
Just wondering how BSA is going to conduct an independent review if they are responsible for the department.
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#2094223 - 08/19/16 02:50 PM Re: Anyone have RDC function overseen by BSA officer Cher
thomasj Offline
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Joined: Mar 2001
Posts: 5,063
Pennsylvania
Please delete this thread before someone here gets the idea that I can oversee RDC in addition to everything else... laugh
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#2094241 - 08/19/16 03:23 PM Re: Anyone have RDC function overseen by BSA officer rlcarey
Cher Offline
Member
Joined: Oct 2003
Posts: 98
Florida, USA
Randy - our credit dept. doesn't do any of the underwriting now anyway so I don't think that will be an issue. Based on what others are saying here I am wondering even if our underwriting is being done correctly. Does anyone have a sample underwriting form that they could share. Maybe I need to consider moving that piece over to our credit area but I need to be able to convince them that it is necessary first. Our auditors have never criticized our process or recommended that.
Last edited by Cher; 08/19/16 03:27 PM.
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#2094324 - 08/19/16 06:14 PM Re: Anyone have RDC function overseen by BSA officer Cher
EB, CAMS Offline
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Joined: Mar 2009
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flyover country
Our RDC review is a joint effort as many others have indicated. Credit-Lending does the underwriting and credit review. BSA does an initial BSA/AML review and then we have a part in the annual review as well. If BSA does not approve, they get canned though. smile
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#2094347 - 08/19/16 07:05 PM Re: Anyone have RDC function overseen by BSA officer Cher
rlcarey Offline
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Joined: Jul 2001
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Galveston, TX
Originally Posted By Cher
Randy - our credit dept. doesn't do any of the underwriting now anyway so I don't think that will be an issue. Based on what others are saying here I am wondering even if our underwriting is being done correctly. Does anyone have a sample underwriting form that they could share. Maybe I need to consider moving that piece over to our credit area but I need to be able to convince them that it is necessary first. Our auditors have never criticized our process or recommended that.


Your institution needs to refer to the BSA Manual in the Electronic Banking section:

•Creating risk-based parameters that can be used to conduct RDC customer suitability reviews. Parameters may include a list of acceptable industries, standardized underwriting criteria (e.g., credit history, financial statements, and ownership structure of business), and other risk factors (customer’s risk management processes, geographic location, and customer base). When the level of risk warrants, bank staff should consider visiting the customer’s physical location as part of the suitability review. During these visits, the customer’s operational controls and risk management processes should be evaluated.

Also this document that directly refers to the risk mitigation process in the BSA Manual:

https://www.ffiec.gov/pdf/pr011409_rdc_guidance.pdf
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