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#27887 - 08/20/02 05:01 PM Re: Bankersonline Policy Exchange?????
Anonymous
Unregistered

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.

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General Discussion
#27888 - 08/20/02 07:07 PM Re: Bankersonline Policy Exchange?????
Anonymous
Unregistered

AH HA!! Must be an attorney!

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#27889 - 08/20/02 11:45 PM Re: Bankersonline Policy Exchange?????
Anonymous
Unregistered

Are you a paranoid banker or just unregistered?

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#27890 - 08/21/02 01:08 PM Re: Bankersonline Policy Exchange?????
BankerMama Offline
Diamond Poster
BankerMama
Joined: Jun 2001
Posts: 1,543
Both, however, anon on that post only because I was logged off for some unknown reason. That keeps happening.



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#27891 - 08/21/02 02:48 PM Re: Bankersonline Policy Exchange?????
Anonymous
Unregistered

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

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#27892 - 08/21/02 06:51 PM Re: Bankersonline Policy Exchange?????
BankerMama Offline
Diamond Poster
BankerMama
Joined: Jun 2001
Posts: 1,543
Just answering YOUR question! You got a problem with that??

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#27893 - 08/21/02 07:02 PM Re: Bankersonline Policy Exchange?????
MackenzieS Offline
Diamond Poster
MackenzieS
Joined: Jul 2002
Posts: 1,722
Oklahoma
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?

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#27894 - 08/21/02 07:10 PM Re: Bankersonline Policy Exchange?????
deppfan Offline
Power Poster
Joined: Dec 2000
Posts: 5,184
All over the map.
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!
_________________________
On the road again.....I just can't wait to get on the road again.

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#27895 - 08/21/02 08:09 PM Re: Bankersonline Policy Exchange?????
BankerMama Offline
Diamond Poster
BankerMama
Joined: Jun 2001
Posts: 1,543
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!)

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#27896 - 08/21/02 08:25 PM Re: Bankersonline Policy Exchange?????
Sinatra Fan Offline
Power Poster
Sinatra Fan
Joined: Jul 2002
Posts: 5,568
New Jersey
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.
_________________________
Management is doing things right; leadership is doing the right things. Peter Drucker

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#27897 - 08/21/02 09:58 PM Re: Bankersonline Policy Exchange?????
Anonymous
Unregistered

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.

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#27898 - 08/21/02 10:05 PM Re: Bankersonline Policy Exchange?????
Anonymous
Unregistered

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

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#27899 - 08/21/02 10:13 PM Re: Bankersonline Policy Exchange?????
wlavoie Offline
Gold Star
wlavoie
Joined: Jul 2002
Posts: 338
Hell's Canyon
Curious as to the regulation that requires outgoing wire payees be checked against the OFAC list...Is it in writing somewhere?
_________________________
Wendy LaVoie

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#27900 - 08/22/02 01:51 PM Re: Bankersonline Policy Exchange?????
BankerMama Offline
Diamond Poster
BankerMama
Joined: Jun 2001
Posts: 1,543
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.

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#27901 - 08/22/02 02:48 PM Re: Bankersonline Policy Exchange?????
Anonymous
Unregistered

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.

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#27902 - 08/22/02 02:57 PM Re: Bankersonline Policy Exchange?????
Anonymous
Unregistered

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."

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#27903 - 08/22/02 03:00 PM Re: Bankersonline Policy Exchange?????
Dave M_TCA Offline
Platinum Poster
Dave M_TCA
Joined: Oct 2000
Posts: 686
Wherever my most benevolent em...
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.
_________________________
David J Mulkerin, CRCM
All opinions expressed are mine and not those of my employer and are not to be taken as legal advice.

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#27904 - 08/22/02 03:41 PM Re: Bankersonline Policy Exchange?????
downstown Offline
Gold Star
Joined: Aug 2001
Posts: 295
St. Louis, MO
I think this is the citation: ยง103.121(b)(5)[if I followed the trail correctly].

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#27905 - 08/22/02 11:10 PM Re: Bankersonline Policy Exchange?????
Anonymous
Unregistered

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.

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#27906 - 08/23/02 02:39 PM Re: Bankersonline Policy Exchange?????
downstown Offline
Gold Star
Joined: Aug 2001
Posts: 295
St. Louis, MO
You are correct that a written notice is not required. The notice may be verbal.

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