Skip to content
BOL Conferences
Thread Options
#2260340 - 09/28/21 04:09 PM DOEP Annual Review
JennKK2 Offline
Gold Star
Joined: Nov 2006
Posts: 315
-
does everyone have the BSA Exemption annual review form signed by the Phase II customer? if as a bank you can, due to a separate account maintained, say for lottery sales; prove the ineligible activities do not exceed 50% - not have the form signed.
_________________________
plan your Work and Work your Plan

Return to Top
BSA/AML/CIP/OFAC Forum
#2260342 - 09/28/21 04:23 PM Re: DOEP Annual Review JennKK2
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,225
Galveston, TX
What does the signature buy you?
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2260348 - 09/28/21 05:58 PM Re: DOEP Annual Review JennKK2
Alison Offline
New Poster
Joined: Jul 2018
Posts: 9
Hi JennKK2-
We do not have a signature line for the customer on our BSA Exemption Annual Review Form.

Return to Top
#2260350 - 09/28/21 06:11 PM Re: DOEP Annual Review JennKK2
P*Q Offline

Power Poster
P*Q
Joined: May 2001
Posts: 8,458
Somewhere
No signature. And we look up their stats in Verafin as evidence that there is minimal revenue due to lottery sales.

Return to Top
#2260356 - 09/28/21 06:32 PM Re: DOEP Annual Review JennKK2
JennKK2 Offline
Gold Star
Joined: Nov 2006
Posts: 315
-
hmmmmm
during a FDIC exam it was noted i was not using the appropriate form as the "Customer Signature line" was omitted. it was then pointed out to have the customer sign attesting to the % facts. I had never had this pointed out before, nor had i ever obtained a customer signature. We at the time only had one phase II who had a separate account for lottery so it was easy to prove. I can't find that it is required to obtain one. We now have another phase II who deposits lottery and other sales combined so a bit more challenging. we don't utilize Verafin
Given this recommendation was from the FDIC i asked the board to comment on obtaining a signature or not.

with that said if i DONT HAVE TO HAVE A SIGNATURE then we most likely won't
_________________________
plan your Work and Work your Plan

Return to Top
#2260358 - 09/28/21 06:59 PM Re: DOEP Annual Review JennKK2
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,225
Galveston, TX
" i was not using the appropriate form as the "Customer Signature line" was omitted."

What form, there is no "form"? The FDIC might want to review the FinCEN information on what constitutes revenue from the sales of lottery tickets - it is only the merchant's cut, which is usually like $.05 a ticket. They either have to have a pretty poor operation or sell a gob of lottery tickets to not qualify.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2267259 - 03/07/22 08:59 PM Re: DOEP Annual Review rlcarey
Victoria S Offline
Member
Joined: Jul 2015
Posts: 96
$.05 per ticket- I did not realize that.

Thanks.

Return to Top
#2267264 - 03/07/22 09:24 PM Re: DOEP Annual Review JennKK2
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,700
The Country
It might be as simple as altering the form and removing the Customer Signature line.
We do not have our customers sign the form.
_________________________
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

Return to Top
#2267722 - 03/16/22 02:09 PM Re: DOEP Annual Review JennKK2
Goldrose Offline
Member
Joined: Sep 2018
Posts: 66
Yes we do, and if you have an old form you might want to check that it has been updated to include Cannabis in the ineligible activity list.

Return to Top
#2267756 - 03/16/22 06:18 PM Re: DOEP Annual Review JennKK2
JennKK2 Offline
Gold Star
Joined: Nov 2006
Posts: 315
-
Goldrose - where did you obtain a new form regarding the cannabis line?
_________________________
plan your Work and Work your Plan

Return to Top
#2267828 - 03/17/22 04:10 PM Re: DOEP Annual Review JennKK2
Bonkers for BSA Offline
Member
Joined: Oct 2015
Posts: 83
We have the customer sign the form to attest the eligible and ineligible percentages. We've not had any regulatory issues or customer signature issues. We've added a step that our Compliance Officer has to review all of the supporting DOEP information before formally exempting a customer.

Return to Top

Moderator:  Andy_Z