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#379595 - 06/30/05 07:21 PM BSA/AML Exam Procedures Available at BOL
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,408
Cape Cod
BankersOnline has downloaded a copy of the new exam procedures documents released today and placed it on our servers. You may want to check it out and get your copy from us if you're having problems with downloading from the regulator's sites. They may be understandably overtaxed today!
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#379596 - 06/30/05 07:28 PM Re: BSA/AML Exam Procedures Available at BOL
Andy_Z Offline
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Andy_Z
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Posts: 27,378
On the Net
Boy you said it. I spent 45 minutes "on hold" waiting for just one of those documents to download.
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#379597 - 07/01/05 02:25 PM Re: BSA/AML Exam Procedures Available at BOL
LoisLane Offline
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LoisLane
Joined: Oct 2001
Posts: 1,570
Wisteria Lane..
What did all of you think about the Procedure's discussion of SAR filing? Do you think it will decrease the defensive SAR filings?
From the Procedures:
The federal banking agencies do not have targeted volumes or “quotas” for SAR and CTR filings for a given bank size or geographic location. Examiners should not criticize a bank solely because the number of SARs or CTRs filed is lower than SARs or CTRs filed by “peer” banks. However, as part of the examination, examiners must review significant changes in the volume or nature of SARs and CTRs filed and assess potential reasons for these changes.
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#379598 - 07/01/05 02:44 PM Re: BSA/AML Exam Procedures Available at BOL
Anonymous
Unregistered

I wish these guidelines were if effect 2 years ago, when an examiner told me we weren't filing enough SARs, especially when compared to our peer banks...the prior year, we filed 13 SARS...that year, we filed 32 SARs...last year, 58...and this year, I project over 100 filings...think I listened ???

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#379599 - 07/05/05 06:42 PM Re: BSA/AML Exam Procedures Available at BOL
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
I cannot access the document.
Does anyone have it as a word doc that you could share with me?
Thanks.

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#379600 - 07/05/05 10:43 PM Re: BSA/AML Exam Procedures Available at BOL
Anonymous
Unregistered

I also was wondering if there was a Word version available anywhere. It would sure help when revising polices and procedures to reflect the content of the new manual. Perhaps it could be posted to this website if available.

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#379601 - 07/06/05 12:46 PM Re: BSA/AML Exam Procedures Available at BOL
Ben Hicks Offline
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Joined: Nov 2004
Posts: 9
I converted the 3 .pdf files to 3 Word files and then put all 3 together to make the 330 page document. I would like to eventually hyperlink the references in the text to the appropriate Appendix section.

I was thinking about donating this to BOL but don't know how to do it. It's about 1.6 meg. Thus I would rather for BOL to put this on their server if they are interested than to email it. The conversion wasn't perfect - I think I got the spelling errors, however.

I haven't checked the associated regulator sites to see if they had done a conversion

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#379602 - 08/04/05 02:29 PM Re: BSA/AML Exam Procedures Available at BOL
Anonymous
Unregistered

Is everyone aware of this site already:

http://www.ffiec.gov/bsa_aml_infobase/

and then a link to the procedures in word format:

http://www.ffiec.gov/bsa_aml_infobase/pages_resource_docs/fdic.htm

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#379603 - 08/09/05 07:31 PM Re: BSA/AML Exam Procedures Available at BOL
Anonymous
Unregistered

Does anyone know if the link to FFIEC that has a presentation on the BSA exam is the same thing as the outreach webairs are doing? Since most feel the 3hours are not worth it would anyone recommend this presentation instead?

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#379604 - 08/09/05 07:52 PM Re: BSA/AML Exam Procedures Available at BOL
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Did anyone notice that the BSA webinars begin at 9 am EST! That's 7 am MST and 6 am PST. I'm not sure what time that is for Dawnie (Alaskan time) - 5 am, I think. What time is that in Hawaii (4?)?

Why would they start these so early? If they started them at 1 or 2 pm EST, it would be over before quitting time for all of the bankers on the east coast and not require everyone else to come in so early.

I realize that you can watch the webinar for up to 3 months, but it would nice if the regulatory agencies would be a little more sensitive to those outside the beltway.
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#379605 - 08/09/05 08:06 PM Re: BSA/AML Exam Procedures Available at BOL
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
They said they were doing the outreach sessions in the a.m. and examiner training in the p.m.
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#379606 - 08/10/05 02:05 PM Re: BSA/AML Exam Procedures Available at BOL
Anonymous
Unregistered

Is there an executive summary of this somwhere that could be used and presented to the board?

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#379607 - 08/12/05 03:45 PM Re: BSA/AML Exam Procedures Available at BOL
etm614 Offline
Platinum Poster
etm614
Joined: Jan 2003
Posts: 695
Massachusetts
Kaybee - you're right. Being a Monday for the NYC session gives the examiners time to travel to the Regional Office for their training.

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#379608 - 08/12/05 11:22 PM Re: BSA/AML Exam Procedures Available at BOL
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
My understanding that the NYC session will be simulcast and that it will also be on the FFIEC web site for three months after the session takes place. They've gone out of their way to make the info available.
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#379609 - 09/28/05 10:30 PM Re: BSA/AML Exam Procedures Available at BOL
Txgrown Offline
New Poster
Joined: Sep 2004
Posts: 15
We just had a BSA audit and the auditor is telling us that we should develop a way of reviewing our Commercial accounts at least yearly to determine if their business registration and organization is still operating in Good Standing and develop a check list for when the DBA papers expire and we should obtain a new one. Has anyone heard of this being part of the new rules?

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#379610 - 09/29/05 11:27 AM Re: BSA/AML Exam Procedures Available at BOL
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
You should review the sections of the new manual beginning at page 164 and 269. (Page numbers, not PDF file) They contain no such explicit, across the board recommendation.

What you describe would be appropriate for corporate customers whom you have identified as high risk or whose registration and licensure requirements are crucial; e.g. MSBs & NBFIs. It might be appropriate for non U.S. companies and companies with whom you have lending relationships. As far as an annual verification for all companies, it's a waste of time.

I suggest you go back to the EIC and seek a clarification or a citation. Offer to do what was requested on those companies you identify as high risk and see if that is acceptable.
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#379611 - 09/30/05 12:42 AM Re: BSA/AML Exam Procedures Available at BOL
Princess Romeo Offline

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Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
This would not be a part of BSA, but many banks do set a "tickler" for Ficticious Name Filings and request their customer submit a new one when the old one expires.

The reason is simple - if your customer's DBA expires, and someone else files that same DBA, yet you are still accepting items payable to the DBA for the benefit of your customer, then you may end up on the sticky end of some legal action. This has happened when a person sells the business to another, but perhaps negotiations did not go so well....

Verifying corporate Good Standing is typically done on the credit side whenever a loan renews.
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