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#2097525 - 09/08/16 06:25 PM BSA Responsibilities for Participation Loans
Daisy Doodle Offline
Diamond Poster
Joined: Feb 2014
Posts: 1,030
Southern U.S.
I've been hunting around to understand our responsibilities if we purchase a share of a loan.

CIP - There is a 'purchased asset exemption' so I don't need to worry about that. Right?
314a - Saw a thread where Ken P says there is no exemption stated so we may be responsible for that
OFAC - could not find any guidance on this. How do others handle? Reliance provision in contract? Set up on core system?

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#2097527 - 09/08/16 06:29 PM Re: BSA Responsibilities for Participation Loans Daisy Doodle
rlcarey Offline
10K Club
Joined: Jul 2001
Posts: 77,207
Galveston, TX
CIP - Correct.
314a - You remain responsible
OFAC - Most participation loans are set up on the core with a CIF and are subjected to periodic scrubbing, as with all CIF records.
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