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#2231095 - 02/14/20 08:27 PM Monetary instruments & non-customers
JennKK2 Offline
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ok I know, I know, but ..
1. does anyone sell MI to non-customers?
2. if so, are you checking payee and remitter against OFAC before the transaction?
3. do you check the payee when a MI is purchased by a customer?
4. do you have dollar thresholds for any of the above scenarios?


thank you
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#2231099 - 02/14/20 08:35 PM Re: Monetary instruments & non-customers JennKK2
JWills, CRCM Offline
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JWills, CRCM
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The Mitten State

1. does anyone sell MI to non-customers? Yes we do

2. if so, are you checking payee and remitter against OFAC before the transaction? Yes we do

3. do you check the payee when a MI is purchased by a customer? We check the payee if it is a non customer

4. do you have dollar thresholds for any of the above scenarios? It is up to the manager to decide if they will sell to a non customer. Most times they are people that we know within the community, but if the situation is on the strange side, we tell them they do not have to sell to them.
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#2231135 - 02/17/20 03:56 PM Re: Monetary instruments & non-customers JennKK2
ComplianceGurl Offline
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Joined: Jul 2007
Posts: 496
1. No, we do not sell to noncustomers.
2. n/a
3. No, we do not check the payee when a MI is purchased by a customer. (We are asked this at every audit/exam. Senior management feels this is a low risk area and the board has approved it as such. We only sell cashiers checks, no money orders, prepaid access cards, etc. So far examiners have been OK with this.)
4. No.

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#2231179 - 02/18/20 05:35 PM Re: Monetary instruments & non-customers JennKK2
Sunshine Lady Offline
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Sunshine Lady
Joined: Apr 2014
Posts: 578

1. does anyone sell MI to non-customers? No
2. if so, are you checking payee and remitter against OFAC before the transaction? - N/A
3. do you check the payee when a MI is purchased by a customer? - No we have this in our BSA policy that we will take the risk
4. do you have dollar thresholds for any of the above scenarios? - No
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#2231357 - 02/20/20 02:51 PM Re: Monetary instruments & non-customers JennKK2
JennKK2 Offline
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outstanding thank you for your replies!
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#2231521 - 02/24/20 12:18 PM Re: Monetary instruments & non-customers JennKK2
New Manager Offline
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Joined: Jan 2004
Posts: 134
1. does anyone sell MI to non-customers? No, but we'll make an exception from time to time when it makes sense.
2. if so, are you checking payee and remitter against OFAC before the transaction? We sell official checks only, no money orders. Yes, it's built into our core system to do it automatically. It also gets checked by the AML software when the files are transmitted overnight.
3. do you check the payee when a MI is purchased by a customer? See #3
4. do you have dollar thresholds for any of the above scenarios? No

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#2247694 - 01/14/21 08:31 PM Re: Monetary instruments & non-customers JennKK2
terpsfan Offline
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Joined: Feb 2007
Posts: 1,862
If you have a potential hit on a payee based on name only what information do you request from the customer or do you just refuse to issue the check? The customer may not know the address or DOB of the payee.

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#2247698 - 01/14/21 08:52 PM Re: Monetary instruments & non-customers JennKK2
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 75,540
Galveston, TX
Nothing like reviving an 11 month old thread smile Or is this a new rather than a rhetorical question?
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#2247704 - 01/14/21 09:59 PM Re: Monetary instruments & non-customers JennKK2
RockChucker, CAMS Offline
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The Country
I've never understood the aversion for some when people revive older threads. What am I missing?
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#2247707 - 01/14/21 10:12 PM Re: Monetary instruments & non-customers JennKK2
rlcarey Online
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Galveston, TX
Well, for one reason - the original posters have long moved on from the subject - especially if it occurs in the anonymous thread. And posting a new question may be best served in a new thread. Maybe it is just me, but I could not tell if tersfan was asking a new question to the group or asking the question of the previous posters.

However, if it was a new question, if you are going to bother running OFAC and you get a hit that you cannot clear - I am not sure how you can issue the instrument. So therefore I saw the question as sort of rhetorical.
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#2247708 - 01/14/21 10:18 PM Re: Monetary instruments & non-customers JennKK2
terpsfan Offline
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Joined: Feb 2007
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I came across this thread while trying to find information on my question so I thought I would expand on this existing thread as it was so closely related. Thanks for you help.

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