Skip to content
BOL Conferences
Thread Options
#285972 - 12/08/04 02:32 PM BSA/CIP Risk Assessment Policies
Anonymous
Unregistered

Does anyone have a copy of thie risk assessment policies for BSA or CIP that they would be willing to email or fax me? I have just recently been promoted to this position and need to get something in place this week! If anyone out there can help me - let me know and I'll post my email address and fax number in my next post. (I'd really appreciate any help)

Return to Top
BSA/AML/CIP/OFAC Forum
#285973 - 12/08/04 02:36 PM Re: BSA/CIP Risk Assessment Policies
waldensouth Offline
Power Poster
waldensouth
Joined: Nov 2001
Posts: 7,984
FINALLY ABOVE the gnat line
Are you referring to customer risk assessment or the risk assessment for the bank? A good customer risk assessment is posted in banker's tools (I think). We used the OCC BSA risk assessment to ascertain risk on the bank level.
_________________________
"Once you learn to read, you will be forever free."

- Frederick Douglass




My Opinion Only.

Return to Top
#285974 - 12/08/04 02:39 PM Re: BSA/CIP Risk Assessment Policies
KKatz Offline
New Poster
Joined: Dec 2004
Posts: 2
I am referring to policies on risk assessment for the bank.

Return to Top
#285975 - 12/08/04 07:29 PM Re: BSA/CIP Risk Assessment Policies
Deena Offline
Power Poster
Deena
Joined: Nov 2000
Posts: 2,701
PA
Quote:

We used the OCC BSA risk assessment to ascertain risk on the bank level.





waldensouth, can you tell me where to find this?
_________________________
Opinions expressed are mine and not necessarily those of my employer.

Return to Top
#285976 - 12/08/04 07:34 PM Re: BSA/CIP Risk Assessment Policies
waldensouth Offline
Power Poster
waldensouth
Joined: Nov 2001
Posts: 7,984
FINALLY ABOVE the gnat line
Community Bank Supervision Handbook, Risk Assessment and Appendix A. They have various risk assessments for various areas of the bank. You just have to scroll down until you find the one for BSA. The appendix is the worksheet.
_________________________
"Once you learn to read, you will be forever free."

- Frederick Douglass




My Opinion Only.

Return to Top
#285977 - 12/08/04 08:00 PM Re: BSA/CIP Risk Assessment Policies
Deena Offline
Power Poster
Deena
Joined: Nov 2000
Posts: 2,701
PA
Thanks very much - I think that's the only place I didn't look. We're a Fed bank and I'm not too familiar with how the OCC manuals are set up.
_________________________
Opinions expressed are mine and not necessarily those of my employer.

Return to Top
#285978 - 12/08/04 09:30 PM Re: BSA/CIP Risk Assessment Policies
waldensouth Offline
Power Poster
waldensouth
Joined: Nov 2001
Posts: 7,984
FINALLY ABOVE the gnat line
Calvin Hagins (OCC Examiner) told me about it at the compliance conference earlier this year.
_________________________
"Once you learn to read, you will be forever free."

- Frederick Douglass




My Opinion Only.

Return to Top
#285979 - 12/10/04 11:48 PM Re: BSA/CIP Risk Assessment Policies
Compliance Geek Offline
100 Club
Compliance Geek
Joined: Jul 2004
Posts: 141
A Mile High
Help! I have been all over the OCC's website and I can't locate Appendix A. I got to the Community Bank Supervision Handbook (barely), but it has no Appendix A.

Thanks.
_________________________
My employer will rapidly disavow any connection of any kind to any posting I have made or may now or in the future make.

Return to Top
#285980 - 12/10/04 11:51 PM Re: BSA/CIP Risk Assessment Policies
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
The Appendices are BELOW the link to the manual. Here you go.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#285981 - 12/11/04 12:31 PM Re: BSA/CIP Risk Assessment Policies
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
After following Kaybee's gracious link, go to page 168 in the document. This is an excellent resource for those charged with doing a risk assessment who are currently looking at a blank piece of paper.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#285982 - 12/15/04 08:46 PM Re: BSA/CIP Risk Assessment Policies
Auditman Offline
100 Club
Joined: Nov 2004
Posts: 132
This is very helpful. Is there a similar resource that focuses on CIP risk indicators?

Return to Top
#285983 - 12/17/04 10:22 PM Re: BSA/CIP Risk Assessment Policies
Anonymous
Unregistered

I would also be interested in CIP risk indicators.

Return to Top
#285984 - 12/28/04 04:09 PM Re: BSA/CIP Risk Assessment Policies
Anonymous
Unregistered

Since the CIP is supposed to be "risk-based," it seems like there should be some CIP "risk indicators." Can anyone help?

Return to Top
#285985 - 12/30/04 09:33 PM Re: BSA/CIP Risk Assessment Policies
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
CIP risk indicators primarily center on HOW he customer came to the bank and the resultant difficulty in validating the ID provided. Face to face is lower risk than internet, for example and you would have to take greater pains to validate the ID submitted. One account holder applying in person and the co-account holder not being present is higher risk than both being present in the branch. Loans coming in through dealers would present a higher risk because the bank is relying on a 3rd party to obtain the info rather than being totally in control of the situation.

You get the idea.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#285986 - 01/04/05 06:30 PM Re: BSA/CIP Risk Assessment Policies
Boomer Offline
100 Club
Boomer
Joined: Apr 2004
Posts: 135
Southwest Florida
Can anyone direct me to where I can find information on CIP risk ratings for loans. I am being told that CIP risk ratings for loans is not necessary???

Return to Top
#285987 - 01/04/05 08:40 PM Re: BSA/CIP Risk Assessment Policies
GreatBlue Offline
Diamond Poster
GreatBlue
Joined: Feb 2003
Posts: 2,362
Colorado
Risk ratings? It may be that that is an internally developed concept. Your CIP program is supposed to be developed based on an analysis of risks, but the CIP regulation does not require risk ratings.
_________________________
Opinions are mine and not necessarily my employer's.

Return to Top
#285988 - 01/15/05 03:53 AM Re: BSA/CIP Risk Assessment Policies
Anonymous
Unregistered

Do you know how to contact Calvin Hagins.....I talked to him recently, but need to asked him for more information.

Return to Top

Moderator:  Andy_Z