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#480575 - 01/10/06 04:39 PM Money Laundering Risk System
THSCPA Offline
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Joined: Sep 2004
Posts: 112
New York
I have a question on the new MLR. When computing the average daily volume, how many days activity are we expected to use when computing our averages? Thanks

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#480576 - 01/10/06 07:10 PM Re: Money Laundering Risk System
nemsi Offline
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Joined: Nov 2005
Posts: 383
I also have a question. When calculating balance on debit card- are you using POS limit? This is very time consuming.

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#480577 - 01/20/06 04:53 PM Re: Money Laundering Risk System
Tillie Offline
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Tillie
Joined: Apr 2003
Posts: 266
I have a question, too! When completing the Risk Summary Form, what do they mean by Retail Transactions? I am presuming they mean that we are the retailer so they are wanting to know how many travelers' checks, etc that we sold.
This has been very time consuming for us too!

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#480578 - 01/25/06 05:11 PM Re: Money Laundering Risk System
Y M I Here Offline
New Poster
Y M I Here
Joined: Jul 2005
Posts: 13
MN
According to the OCC representative I spoke with:

When calculating the average daily volume they would like you to use 250 days versus 365.

When calculating balance on debit cards . . . They are talking about stored value cards and not actual ATM/Debit Cards.

Again, according to the rep that I spoke to regarding "retail transactions" she stated to use everything except Bank to Bank transactions. For example she mentioned Fed Funds Sold would not be a retail transaction. However, if you wire loan proceeds to a title company, this would be a retail transaction.

I hope this helps clarify questions for all of you.

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#480579 - 01/27/06 06:40 PM Re: Money Laundering Risk System
THSCPA Offline
100 Club
Joined: Sep 2004
Posts: 112
New York
I have a quick question. For the wire transfer activities and ACH, do they want just transactions originated by the Bank or average originators and receipts?

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#480580 - 01/30/06 02:48 PM Re: Money Laundering Risk System
bamccull Offline
Member
bamccull
Joined: Jan 2004
Posts: 50
Hurricane Country
I asked this question and was told ACH and Wire Transfers are both (received and originated or incoming and outgoing).
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