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