I've read the Private Banking sections in the FFIEC manual. Is there any guidance on how many of the listed items have to be offered before an account is considered Private Banking? My situation is thus: Checking account, $500 overdraft, online banking and mobile banking, special mortgage loan product w/ no down payment. The product is not designed for "high net worth customers", but is more for newly-minted (and highly-indebted) doctors who have the potential to become high net worth customers in the future. Is that close enough to be Private Banking??

Generally, "private banking" can be broadly defined as providing personalized financial services to wealthy clients. However, in a specific BSA/AML context the term is limited to an account:

* for a non U.S. person which
* requires a minimum deposit of $1MM.

That does not sound like the folks you are talking about. If yours is a community bank, a response to a pre-examination questionnaire that indicates your bank is involved in "private banking" will probably cause your EIC to swallow his or her tongue.

HA! Thanks Ken!