Skip to content
BOL Conferences
Thread Options
#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.

Return to Top
BSA/AML/CIP/OFAC Forum
#2094154 - 08/19/16 02:55 AM Re: Anyone have RDC function overseen by BSA officer Cher
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,226
Galveston, TX
Unless you have a BSA Officer that is skilled in credit underwriting, why would it even be suggested??
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2094170 - 08/19/16 12:54 PM Re: Anyone have RDC function overseen by BSA officer Cher
banker1976 Offline
Gold Star
Joined: Nov 2005
Posts: 346
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.
_________________________
CAMS
CAFP

Return to Top
#2094185 - 08/19/16 01:42 PM Re: Anyone have RDC function overseen by BSA officer Cher
Beachbum, CRCM Offline
Gold Star
Joined: Dec 2006
Posts: 499
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."
_________________________
What we think, we become.
Buddha

Return to Top
#2094186 - 08/19/16 01:45 PM Re: Anyone have RDC function overseen by BSA officer Cher
Daisy Doodle Offline
Diamond Poster
Joined: Feb 2014
Posts: 1,030
Southern U.S.
RDC in our bank is overseen jointly by Credit and Treasury Management.

Return to Top
#2094200 - 08/19/16 02:15 PM Re: Anyone have RDC function overseen by BSA officer Cher
osucpa Offline
Diamond Poster
Joined: May 2011
Posts: 1,406
Handled in our Treasury Services area.

Return to Top
#2094204 - 08/19/16 02:21 PM Re: Anyone have RDC function overseen by BSA officer Cher
Lilly C Offline
100 Club
Lilly C
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.

Return to Top
#2094205 - 08/19/16 02:22 PM Re: Anyone have RDC function overseen by BSA officer Cher
edAudit Offline
Power Poster
edAudit
Joined: Jul 2008
Posts: 4,796
You are here
Just wondering how BSA is going to conduct an independent review if they are responsible for the department.
_________________________
Opinions can be considered as coming from anywhere but my employer.

CAMS


Return to Top
#2094223 - 08/19/16 02:50 PM Re: Anyone have RDC function overseen by BSA officer Cher
thomasj Offline
Power Poster
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
_________________________
Knowledge is knowing what to say. Wisdom is knowing when to say it.

Return to Top
#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.
Return to Top
#2094324 - 08/19/16 06:14 PM Re: Anyone have RDC function overseen by BSA officer Cher
EB, CAMS Offline
100 Club
EB, CAMS
Joined: Mar 2009
Posts: 133
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
_________________________
It is actually possible for you and I to have different opinions and yet still live peaceably upon this planet.

Return to Top
#2094347 - 08/19/16 07:05 PM Re: Anyone have RDC function overseen by BSA officer Cher
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,226
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
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z