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#224100 - 08/05/04 06:49 PM Physical Address
tjbanker Offline
Gold Star
Joined: Jun 2002
Posts: 310
I am looking for some assistance. Somewhere I had heard that we needed to make sure we had a physical address on our host computer system at the bank and not just a P.O. I tried to do a search on this through the posts and didn't have any luck finding an answer. Which regulation is requiring this? I need to address the staff and always like to have a black and white copy to give them. Thank you for your help.

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BSA/AML/CIP/OFAC Forum
#224101 - 08/05/04 06:57 PM Re: Physical Address
Tink Offline
Member
Joined: Apr 2004
Posts: 59
That would be a part of CIP. Reference 31 CFR 103.121 (b)(2)(i). Click Here

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#224102 - 08/06/04 02:07 PM Re: Physical Address
GreatBlue Offline
Diamond Poster
GreatBlue
Joined: Feb 2003
Posts: 2,362
Colorado
It is CIP that requires a physical address, but it doesn't say anything about where it has to be stored.
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#224103 - 08/06/04 02:55 PM Re: Physical Address
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Great Blue is correct, BSA's CIP requirements do not specify where you keep the information, only that it be kept for the requisite period and be reasonably accessible. There may have been some official pronouncement within your institution that it had to be on the "host computer system," but that does not come from law or regulation.
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#224104 - 08/07/04 09:55 PM Re: Physical Address
Ann Offline
Platinum Poster
Joined: Jul 2001
Posts: 564
South Carolina
Perhaps this relates to the conditional exception to the TRAVEL RULE which expired on July 1, 2004.

Financial institutions are required to include certain information in transmittal orders relating to transmittals of funds of $3,000 or more, which must travel with the order throughout the funds transmittal sequence.

Among these requirements is that each transmittor's financial institution and intermediary financial institution include in a transmittal order the transmittor's name and address. The term address means either the transmittor's street address, or a mailing address so long as the financial institution maintains the transmittor's street address on file.

Our wire transfer system pulls the address of our customers who originate wires from the CIF record, so physical addresses are important. Please do a search on Travel Rule for more information.

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#224105 - 08/07/04 10:11 PM Re: Physical Address
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Ann,
I think that's a very intuitive guess...
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#224106 - 08/09/04 04:07 PM Re: Physical Address
Anonymous
Unregistered

We have all the necessary originator information through a system similar to yours. Our problem is the beneficiary's information. We use Fed Wire which allows for beneficiary address information. I read the law to mean that we only need the benficiaries address to travel with the transfer if it was supplied by the originator. Is this your understanding as well? (We always have the beneficiary's account number).

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#224107 - 08/09/04 06:02 PM Re: Physical Address
Ann Offline
Platinum Poster
Joined: Jul 2001
Posts: 564
South Carolina
Yes, that is my understanding as well. If you have the address information on the beneficiary, send it; however, the regulation does not require you to get it.

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#224108 - 08/09/04 06:16 PM Re: Physical Address
Anonymous
Unregistered

Thank you, Ann!

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