Reviving this thread please. Recent FDIC Exam Sept 2019 and BSA Audit Feb 2019 both site us for not spelling out triggering events in our Beneficial Ownership (BO) Policy. I am leaning toward putting "triggering event(s)" in the BO Procedures and not the BO Policy. Both the exam and audit list multiple items as triggers: ownership/management change, uptick in CTR filings, SAR filings, law enforcement subpoenas, 314a match, open new account, time deposit change in terms, loan extension/modifications, changes to existing accounts, etc. Since this thread and tagged previous thread are from 2018 have the triggers been expanded or is the only trigger per bo regulation the opening of a new account, my research has been inconclusive? Thanks in advance for your help.