At this point no one is posting policies. You have a good point relating to attorney's although your language is a little too disagreeable from my point of view.

AH HA!! Must be an attorney!

Are you a paranoid banker or just unregistered?

Both, however, anon on that post only because I was logged off for some unknown reason. That keeps happening.

So, what is the purpose of your last post to this thread?

Just answering YOUR question! You got a problem with that??

Vegan2 - go see Bankers Tools: Policies & Procedures. I guess the question is if we would like to have to Moderators post one of our sample policies, how would we go about it?

I am still polishing the CIP that is posted in the Bankers Tools area, and just realized that I did not address the requirement of giving notice to customers. Sorry about that!

I would like to appologize for coming across as "snippy" on any of my posts here. I really appreciate all the help some of you have so freely offered. Looks to me like that is what BOL is all about.....helping each other. (Even the attorneys and regulators!)

I am willing to share the two policies that I have written with anyone who would like them: a web site policy (admittedly very simplistic, like our web site), and a lending policy (don't read and operate heavy machinery). Just give me your non-BOL e-mail address and I'll be happy to send them to you.

I've looked at the Tools section, but there are limited examples, given the number of possible posters. I would like to see a simple list of the policies that are mandatory, along with an ancillary list of those that are needed if you offer a specific service or product. Also, the an overview of how policies can be combined would be helpful. Finally, small, start up bank examples would be the most helpful.

I do - I didn't ask you are question.

Curious as to the regulation that requires outgoing wire payees be checked against the OFAC list...Is it in writing somewhere?

You ask the purpose of my last question. I answered it. I apologized for being "snippy".....I have nothing further to say to you on this matter.

Good question. I didn't ask the FDIC or state regulator for reference documentation, but they left us with no doubt that outgoing wire payee names need to be checked.

Now I'm hoping that this needs to be done, as sometimes "tasks" get started based on an individual regulators interpretation of regulations and it spreads from there, but in this case it seems logical given the purpose of the regulation.

Could you post the reference that requires customer notification? I'm thinking at the time new accounts is going through the ID process, they are not working with a customer, what do we need to provide "prospects."

wlavoie,

It's in the OFAC regulations, the prohibitions on sending/receiving $$ to/from anyone on the blocked listings. The only way to do that is to check all wires against the OFAC listings. You can find the OFAC info here.

I think this is the citation: §103.121(b)(5)[if I followed the trail correctly].

Ron:

I looked at that reference, but I'm thinking that an actual notice, something in writing, is not necessarily what is required. It seems like simply incorporating the ID issues within the new accounts process is notice - and that is already part of the process. It's not like someone needs to go ahead with the opening of account if they are put off by the ID process.

You are correct that a written notice is not required. The notice may be verbal.