Has anyone had an examiner question or push for alert thresholds to be based on risk? With different thresholds for each risk category so low risk customers would have one set of parameters for cash activity compared to moderate risk customers?
In a past institutions, I had two sets of thresholds one for High Risk Customers and one set for non High Risk Customers; our examiner loved it. Currently we add 10 points to the risk score of all alerts for High Risk customers.