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#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)

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#285973 - 12/08/04 02:36 PM Re: BSA/CIP Risk Assessment Policies
waldensouth Offline
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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.
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#285974 - 12/08/04 02:39 PM Re: BSA/CIP Risk Assessment Policies
KKatz Offline
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I am referring to policies on risk assessment for the bank.

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#285975 - 12/08/04 07:29 PM Re: BSA/CIP Risk Assessment Policies
Deena Offline
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Deena
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Quote:

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





waldensouth, can you tell me where to find this?
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#285976 - 12/08/04 07:34 PM Re: BSA/CIP Risk Assessment Policies
waldensouth Offline
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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.
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"Once you learn to read, you will be forever free."

- Frederick Douglass




My Opinion Only.

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#285977 - 12/08/04 08:00 PM Re: BSA/CIP Risk Assessment Policies
Deena Offline
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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.
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#285978 - 12/08/04 09:30 PM Re: BSA/CIP Risk Assessment Policies
waldensouth Offline
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Calvin Hagins (OCC Examiner) told me about it at the compliance conference earlier this year.
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"Once you learn to read, you will be forever free."

- Frederick Douglass




My Opinion Only.

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#285979 - 12/10/04 11:48 PM Re: BSA/CIP Risk Assessment Policies
Compliance Geek Offline
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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.
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#285980 - 12/10/04 11:51 PM Re: BSA/CIP Risk Assessment Policies
Kathleen O. Blanchard Offline

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The Appendices are BELOW the link to the manual. Here you go.
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#285981 - 12/11/04 12:31 PM Re: BSA/CIP Risk Assessment Policies
Elwood P. Dowd Offline
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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.
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#285982 - 12/15/04 08:46 PM Re: BSA/CIP Risk Assessment Policies
Auditman Offline
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Posts: 132
This is very helpful. Is there a similar resource that focuses on CIP risk indicators?

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

I would also be interested in CIP risk indicators.

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#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?

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

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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

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#285986 - 01/04/05 06:30 PM Re: BSA/CIP Risk Assessment Policies
Boomer Offline
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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???

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#285987 - 01/04/05 08:40 PM Re: BSA/CIP Risk Assessment Policies
GreatBlue Offline
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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.
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#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.

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