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#36530 - 10/10/02 02:06 PM
CIP NEWS!!!
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Diamond Poster
Joined: Nov 2000
Posts: 1,830
District of Columbia
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I have just been notified by Bill Hood at the ABA that John Byrne has recieved notification from Treasury that Banks will not be required to comply with the §326 CIP provisions by 10/25.The communication states: "ABA has been asked by several bank agencies and the Treasury Department to alert our members that the implementation date for Section 326 (Account Opening Verification) will NOT be October 26, 2002 but a "reasonable" period of time to be determined shortly.
We realize that an official announcement and a specific time frame is needed and we hope to get that information soon."
Leslie
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Being kind is more important than being important.
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#36531 - 10/10/02 02:13 PM
Re: CIP NEWS!!!
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Diamond Poster
Joined: Jun 2001
Posts: 1,543
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#36532 - 10/10/02 02:15 PM
Re: CIP NEWS!!!
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Anonymous
Unregistered
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OCC is on site at our bank conducting a compliance exam. They also received notification today that they can alleviate our stress by letting us know that there will be a delay in the issuance of the final rule and that, YES, we will then also be given a reasonable time period to implement. IT IS TRUE!!!!!!!
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#36535 - 10/10/02 07:14 PM
Re: CIP NEWS!!!
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Diamond Poster
Joined: Aug 2001
Posts: 1,033
Marysville, Ca.
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OCC received notification of such this fact. Yes, yes, yes. As Andy says, the power of comment letters!
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Tina A Sweet-Williams AVP Special Assets mailto:tsweet@goldcountrynb.com
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#36537 - 10/11/02 04:31 PM
Re: CIP NEWS!!!
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Diamond Poster
Joined: Aug 2001
Posts: 1,033
Marysville, Ca.
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Bonnie:
You go!
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Tina A Sweet-Williams AVP Special Assets mailto:tsweet@goldcountrynb.com
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#36541 - 10/11/02 07:31 PM
Re: CIP NEWS!!!
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Diamond Poster
Joined: Aug 2001
Posts: 1,033
Marysville, Ca.
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I just received this in the Washington Weekly. What are your thoughts? Customer Identification Deadline
Treasury is working hard to meet the October 25 statutory deadline for issuing final rules regarding Customer Identification Programs (CIP) required by the USA PATRIOT Act. But, unlike some provisions of the USA PATRIOT Act, the statute does not establish a compliance date for CIPs whether or not rules have been issued. Many banks mistakenly believe that compliance is mandated by October 25. The banking regulators have asked Treasury to issue a formal announcement to clear up this misunderstanding.
The ICBA has been assured by federal banking regulators that the final rule, when issued, will incorporate a transition period to allow banks time to implement appropriate compliance procedures. However, until a final rule has been issued, any program or system that is installed based on the proposed rule will likely have to be changed. Moreover, the banking agencies are unlikely to issue examination procedures until a final regulation is in place. Banks with questions about the new customer identification requirements can contact their primary federal regulator or the ICBA.
_________________________
Tina A Sweet-Williams AVP Special Assets mailto:tsweet@goldcountrynb.com
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#36543 - 10/11/02 07:45 PM
Re: CIP NEWS!!!
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Diamond Poster
Joined: Aug 2001
Posts: 1,033
Marysville, Ca.
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You bet!
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Tina A Sweet-Williams AVP Special Assets mailto:tsweet@goldcountrynb.com
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#36544 - 10/11/02 07:46 PM
Re: CIP NEWS!!!
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Diamond Poster
Joined: Nov 2000
Posts: 1,830
District of Columbia
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Tina, i agree with the article - how can financial institutions be expected to put procedures in place without knowing what those procedures will entail? Of course we will be given an "honeymoon" period in whaich to implement. I know the ABA asked for a year, but I would be happy if it could be the end of January. What people are confued about is that the ACT states the REGULATIONS must be written by 10/25 - not that it has to be in place by then. This is the regulator's deadline - not ours. What REALLY hacks me off are vendors who are trying to make a buck off this mistaken beleif that banks have to be in compliance by 10/25. For example, I recieved the follwing from a well known compliance vendor:
"... Get XXXXX's new electronic CIP Toolkit! As you likely know, Customer Identification Program (CIP) regulations may not be finalized until late October...just when your institution's CIP needs to be finalized as well!"
To me this kind of marketing is CRAP! First of all, we don't have to be in compliance by 10/25, and secondly - how do they know any more about what is going to be written in the new regulations than the rest of us?
OKAY - see what you did! You got me on my soapbox again! (I have three little Bears in my office that are "See no evil, hear no evil, and speak no evil. My boss says I need a fourth - POST no evil!) Leslie
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Being kind is more important than being important.
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#36545 - 10/11/02 07:50 PM
Re: CIP NEWS!!!
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10K Club
Joined: Oct 2000
Posts: 27,750
On the Net
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That is what we've been hearing and saying, before they said it 2 days ago. It only makes sense that we can't comply and they can't examine us until the final rules are out.
My question is now, when will the Reg be out. Initially I thought they were still going for 10-25, but now it sounds like they plan to miss that date.
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AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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#36549 - 10/11/02 07:54 PM
Re: CIP NEWS!!!
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Platinum Poster
Joined: Jul 2002
Posts: 832
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Leslie, I agree with you. I have, sitting on my desk, four letters from another well known vendor which read "Are you ready for October 26?". These hit the bank today and every department brought their's to me. I have told the vendor many times that I will let them know if I am interested in their product. Hopefully, I won't need it!
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Marilyn, CRCM
I'd rather be fishing.
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#36550 - 10/11/02 08:23 PM
Re: CIP NEWS!!!
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Diamond Poster
Joined: Apr 2002
Posts: 1,677
SmallTown, USA
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I learned a lesson when I very first began to work in compliance. It was around 87-88, I don't remember exactly which Reg was being implmented/changed but I let a salesman from a very well known forms company talk me into buying some kind of useless forms before those Regs (whatever they were) were final. Spent a good deal of the banks money and ended up throwing out all those forms. To this day, I'm slow (probably too slow) on putting things into place until Regs are final.
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The opinions expressed are mine and do not necessarily reflect those of my employer.
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#36551 - 10/11/02 08:28 PM
Re: CIP NEWS!!!
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100 Club
Joined: Nov 2001
Posts: 243
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#36553 - 10/11/02 09:21 PM
Re: CIP NEWS!!!
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Anonymous
Unregistered
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Here is a link to a press release that the Treasury Dept. had on their web site. It indicates that we will not have to comply with section 326 of the USA Patriot Act or the proposed rules issued on July 23rd until final implementing regulations are issued and become effective. They said that the comment letters revealed substantial issues that the Treasury and federal functional regulators are analyzing as a final rule is prepared. They will provide us with a reasonable amount of time in which to come into compliance. http://www.treas.gov/press/releases/po3530.htm
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