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#2182965 - 06/25/18 03:58 PM Expected activity ranges for personal accounts?
J_G Offline
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Is it common to obtain the expected activity ranges for personal accounts when opening the account? We currently only do this for business accounts, but I'm curious if I should start for personal accounts as well.

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#2182966 - 06/25/18 04:04 PM Re: Expected activity ranges for personal accounts? J_G
Sunshine Lady Offline
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Our AML system lets us set expected behaviors for personal accounts and it helps me a lot. We have set global general behaviors in the system, but we can change them at any time.
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#2182969 - 06/25/18 04:18 PM Re: Expected activity ranges for personal accounts? J_G
P*Q Offline

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Currently we do not but as stated above, our AML system does have a CDD form in which we can collect it, which we will be utilizing in our branches by year end.

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#2182974 - 06/25/18 04:26 PM Re: Expected activity ranges for personal accounts? J_G
rlcarey Offline
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Nothing like creating additional work.
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#2182980 - 06/25/18 04:34 PM Re: Expected activity ranges for personal accounts? J_G
P*Q Offline

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Everyone is entitled to their opinions on this issue. Each of us has our own CDD and EDD program and if gathering this info is useful for our own monitoring purposes then so be it.

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#2182983 - 06/25/18 04:46 PM Re: Expected activity ranges for personal accounts? J_G
MyBrainHurts Offline
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I know of two banks that were pushed hard by the OCC in the Central District to collect this info at account opening. It is of marginal value on your typical household accounts and the customers don't like it.
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#2182985 - 06/25/18 04:54 PM Re: Expected activity ranges for personal accounts? J_G
Richard Insley Offline
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Are there ways to use this additional behavioral data for marketing purposes? Upsales? Add-on services? Product development?
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#2182986 - 06/25/18 04:57 PM Re: Expected activity ranges for personal accounts? J_G
P*Q Offline

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I don't see why there wouldn't be Richard.

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#2182988 - 06/25/18 05:01 PM Re: Expected activity ranges for personal accounts? J_G
rlcarey Offline
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Yes - I know, but I would not do it voluntarily and if a regulator insisted, only after I lost any appeal process. Unless you are dealing with higher risk individuals, like NRAs, it is a exercise in futility. What are you really going to do with the information and as MBH said, customers are not going to like it. Having this information on every little old lady that only gets SSI checks - is it really worth it? Maybe if you have some generic standard CDD questions, like do you plan to do wire transfers, asking them about volumes might come next. But it is like BO information - if someone doesn't want to tell you what they are going to be doing - they will lie. If they do something unusual, your AML monitoring should already pick that up on a new account.
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#2182991 - 06/25/18 05:23 PM Re: Expected activity ranges for personal accounts? J_G
ACBbank Offline
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We are regional bank who was forced to do this for our consumer retail accounts. There is minimal value and it absolutely creates additional work which drives up the cost of the AML Department. However, there really isn't much you can do to push back. SRs are handed out like candy in my area and regulators don't think twice about forcing banks to due additional, low value work for AML in my area.
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#2183022 - 06/25/18 06:51 PM Re: Expected activity ranges for personal accounts? J_G
TryingtoComply Offline
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This information is included in our KYC Questionnaire that we complete interview style at account opening. We have several questions in our KYCQ that help us to identify the sources of income, and PEP status.

I honestly believe that the collection of this information is dependent on your banks profile. We are a business bank and our customers activities are well outside what you would see for a normal consumer with respect to ACH, wire, and even cash and debit card activity.

I think it would be stupid to collect this information if you were a small retail community bank or credit union; however, for a bank like ours it actually does make some sense and having the information has proven useful.
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#2183182 - 06/26/18 05:36 PM Re: Expected activity ranges for personal accounts? MyBrainHurts
Princess Romeo Offline

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Originally Posted By MyBrainHurts
I know of two banks that were pushed hard by the OCC in the Central District to collect this info at account opening. It is of marginal value on your typical household accounts and the customers don't like it.


The OCC in the Western District imposed this requirement about 6 years ago. I see no value to it as most BSA systems can detect unusual patterns in a consumer's account. If someone is getting direct deposits of their paycheck, why would it matter if one week they made 5 withdrawals from an ATM, and the next week they didn't make any withdrawals? And why do I need to contact my customer if they get a direct deposit from their employer at or near year-end that is slightly larger than their usual deposit? Do I really need to pester my customer and ask if they got a year-end bonus? Per the OCC, and I will quote "Yes."

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#2183366 - 06/27/18 07:22 PM Re: Expected activity ranges for personal accounts? J_G
Pat Patriot Act Offline
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If this ever comes up again, show the auditor or examiner this little gem from the new FFIEC Exam Manual CDD Chapter (Page 3):

Quote:
The bank should gather sufficient information about the customer to form an understanding of the nature and purpose of customer relationships at the time of account opening. This understanding may be based on assessments of individual customers or on categories of customers. An understanding based on “categories of customers” means that for certain lower-risk customers, the bank’s understanding of the nature and purpose of a customer relationship can be developed by inherent or self-evident information such as the type of customer, the type of account opened, or the service or product offered.
Last edited by Pat Patriot Act; 06/27/18 07:32 PM.
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