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#2243970 - 10/13/20 05:48 PM Private Banking - Board Policy
MHuff Offline
100 Club
MHuff
Joined: Nov 2006
Posts: 218
LA
We are in the process of preparing to offer private banking services. Our BSA policy is being updated to address PB in accordance with exam manual recommendations. Is a separate board policy needed for private banking?
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General Discussion
#2243971 - 10/13/20 06:12 PM Re: Private Banking - Board Policy MHuff
osucpa Offline
Diamond Poster
Joined: May 2011
Posts: 1,402
I think it depends. If these are products and services already covered in other Policies then probably not. If they are new products and services then probably so.

Just my opinion.

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#2243972 - 10/13/20 06:13 PM Re: Private Banking - Board Policy MHuff
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,188
New York City
There are other areas that will impacted by PB other than BSA. Operationally have you determined what new wires procedures will be required? Are there current policies or procedures that need to be revised to facilitate PB such as compensation?
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#2245703 - 11/19/20 06:21 PM Re: Private Banking - Board Policy MHuff
jsim913 Offline
Junior Member
Joined: Feb 2019
Posts: 45
We added "Private Client Banking" last year but ours is really more a handful of concierge type services (24/7 phone support, metal debit card, courier services, etc). We updated affected policies and procedures (BSA, wires, teller, courier, internal controls, HR, etc) but didn't adopt a separate policy.

"Private" services was immediately latched on to by auditors and regulators and became a whole separate category for testing so be sure to have your documentation and reporting ready to go. We've just started our FRB exam but I don't anticipate issues on that front. If it was more encompassing of the services outline in the FFIEC manual, we probably would have adopted a separate policy to help address the additional scrutiny.

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