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#2256513 - 07/09/21 06:33 PM exam fun: DL info on BO forms
Anonymous
Unregistered

What's frustrating to me is when a regulatory agency designs a form that seems as though it was intentionally crafted to cause exam problems. They failed to require banks to record the driver's license information or any other record of how we verified the identity of a beneficial owner, on the BO forms, yet, when we are examined, we have to prove that we either viewed a driver's license or otherwise verified the identity of each individual, including ones who are not present.

Have any of you redesigned the (terrible) BO form put out by regulators, so as to capture this info directly on the form? This seems like it would make exam experiences a little easier, possibly, unless stupid things would happen like someone writing "existing customer" or an expired DL date on the form.

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#2256515 - 07/09/21 07:41 PM Re: exam fun: DL info on BO forms Anonymous
SmallBankBSA Offline
100 Club
Joined: May 2018
Posts: 147
Yes, we use a form that we created that captures the DL information for the beneficial owner and control owner directly on the form itself.
This form has been through internal audits and regulatory exams with no issues.

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#2256536 - 07/09/21 11:04 PM Re: exam fun: DL info on BO forms Anonymous
Anonymous
Unregistered

Have you had to produce copies of IDs for your exams anyway, or did auditors accept your form's record as proof?

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#2256544 - 07/12/21 01:51 PM Re: exam fun: DL info on BO forms Anonymous
Cbigun Offline
100 Club
Joined: May 2016
Posts: 154
We just had a BSA Exam and our form is provided by our core which does have the information documented on the form. They did not ask for a proof of the DL, even though we did have them.

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