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#2096613 - 09/01/16 05:46 PM Funds Transfer Verification
Michelle Offline
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Good afternoon,
I have always been told that all wire transfers in the amount of $5,000 or more require a second verification by an employee other than the employee that accepted the instruction from the customer. I have been asked where this requirement is stipulated and am not able to locate it. Is it RegJ, UCC-4A, or BSA? I have checked all three with no success.

Thanks!
Michelle

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#2096630 - 09/01/16 06:09 PM Re: Funds Transfer Verification Michelle
rlcarey Offline
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It is an internal control issue.
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#2096634 - 09/01/16 06:14 PM Re: Funds Transfer Verification Michelle
Michelle Offline
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Thank you. Are you saying that it is not required? Because it has been previously included in both internal and external audits.

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#2096642 - 09/01/16 06:21 PM Re: Funds Transfer Verification Michelle
rlcarey Offline
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No, it is not required unless buried somewhere in your State law, which I doubt. Most banks have established various levels for wire transfer approvals based on dollar amounts, as once the wire leaves the bank, it is gone forever.
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#2096695 - 09/01/16 08:30 PM Re: Funds Transfer Verification Michelle
John Burnett Offline
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And if it's stated in your policy as a requirement, it would be appropriate for an auditor or examiner to cite the bank if it failed to follow its own internal controls. And frankly, when auditors and examiners see one unenforced control, their radar is up looking for other unobserved controls.
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#2096696 - 09/01/16 08:32 PM Re: Funds Transfer Verification Michelle
HappyGilmore Offline
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Pulling people out of the ditc...
If it is listed in audits, it is a risk limit/process your bank has in place. No regulatory requirement.

you may also want to check your funds transfer agreement with your customers, it could be embedded there. We have a mandatory callback in ours, but it is a much higher level. A customer may choose to require a callback on any amount based on how they complete the agreement.
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#2096699 - 09/01/16 08:36 PM Re: Funds Transfer Verification Michelle
rlcarey Offline
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Galveston, TX
We have a mandatory callback in ours, but it is a much higher level.

I hope you have some other commercial reasonable security procedures for the lesser amounts or management should be ready to just write these off, if there is a dispute. I'm not sure why approval on the bank side would have anything to do with an agreement with the customer?
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#2096702 - 09/01/16 08:40 PM Re: Funds Transfer Verification Michelle
Amandak Offline
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Joined: Jul 2013
Posts: 80
Wisconsin
It may be dictated by your insurance company. Our insurance policy states we can receive wires via email or fax.

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#2096704 - 09/01/16 08:42 PM Re: Funds Transfer Verification Amandak
rlcarey Offline
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Galveston, TX
Originally Posted By Amandak
It may be dictated by your insurance company. Our insurance policy states we can receive wires via email or fax.


But I also bet is says as long as the bank complies with UCC 4A-202
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#2096743 - 09/02/16 12:54 PM Re: Funds Transfer Verification rlcarey
HappyGilmore Offline
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Pulling people out of the ditc...
Originally Posted By rlcarey
.

I hope you have some other commercial reasonable security procedures for the lesser amounts or management should be ready to just write these off, if there is a dispute.


oh, gosh, never thought of that... eek

of course we do, but I didn't feel the need to provide superfluous information as it didn't provide benefit to the original post
Last edited by HappyGilmore; 09/02/16 01:01 PM.
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