We're having our BSA Exam next month. Can anyone share some good advice? Thank you!

Be organized with all your paperwork and provide whatever they request promptly and neatly.
First impressions go a long way.

Just got done w/ an exam - they liked that we had set up files for all our MSB customers with a form listing MSB products they were involved w/, expected volume, copy of agency agreements, or list of their agents, their bsa policies,etc. I never beleived in putting them in uncomforatble rooms if I had the space, etc like some people do.
I always make examiners comfortable - provide info on local restaurants, make sure they have a phone book, etc.

Just got done too. I had every question organized with documentation/reports along with instructions on how to read some of our reports. I also prepared a overview of our bank and program to give then an idea of how we were set up. I would check in on them in the morning and afternoon to see if I could answer any questions. Be prepared and confident.

Pull and Review your CTRs, SARs, quiz your Customer Service Reps and make sure they all give the same answer on your CIP and Risk Rating requirements when opening new accounts -- and be sure they're following the procedure. Ours were quizzed last time.

We're currently going through a BSA exam. We use a well known third-party software product to do our OFAC checks. The OFAC list that the software checks names against is updated automatically by the software vendor, and we receive email notification whenever the list is updated.

One of the examiner's recommendations (i.e., requirements) is that, on at least a quarterly basis, we "validate" the software by picking some names that were recently added to the OFAC list and submitting those names to the software to verify that they do indeed come up as an OFAC match. I had never heard of that requirement before, but it's something you should be aware of if you are using third-party software.

Get the BSA Examination Core Procedures from FFIEC. This is what the FDIC examiners used when they were here last September. If I would have had it before, we would have been a lot better prepared. CIP was a hot area during our exam, as was OFAC. Good Luck!

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One of the examiner's recommendations (i.e., requirements) is that, on at least a quarterly basis, we "validate" the software by picking some names that were recently added to the OFAC list and submitting those names to the software to verify that they do indeed come up as an OFAC match. I had never heard of that requirement before, but it's something you should be aware of if you are using third-party software.

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The idea comes from page 208 of the BSA/AML Exam Manual, where it says: "If the bank uses an automated system to conduct searches, assess the timing of when updates are made to the system, and when the most recent OFAC changes were made to the system. Also, evaluate whether all of the bank’s databases are run against the automated system, and the frequency upon which searches are made. If there is any doubt regarding the effectiveness of the OFAC filter, then run tests of the system by entering test account names that are the same as or similar to those recently added to the OFAC list to determine whether the system identifies a potential hit."

Two things to notice: First, the tests are to be done " If there is any doubt regarding the effectiveness of the OFAC filter", not periodically. Second, if there is doubt, the language tells the examiner to run the tests. They apparently want you to do this so they won't have to.

I validate the OFAC list whenever it is updated by selectively entering some of the added names and seeing if I receive a hit. I don't validate every name added so it does not take more than a few minutes. I keep evidence of these validations.

That's good to know. I may point that out to the examiner just to see what he says.

All good advice. Recommend you read your Bank's BSA/AML policy to ensure you're following it with regard to processes and procedures for CTR's/SAR's, High Risk Companies, etc, including monitoring/spot checks on monetary logs, wire transfers, and loan activity.

The hot topics at our last exam was CIP on loans and OFAC. Don't expect much scrutiny on what you are doing well. Be honest about your weak areas and have a plan to address them. Good luck.

OTS just finished with us. As JohnL mentioned, we had some inconsistencies between policy and procedure, nothing major, but they really are scrutinizing everything.

Also, Wires, OFAC risk assessment, CIP, Bankwide BSA risk assessment. Be ready...

The hot topic in one of my banks exams today was failure to document Board appointment of the bank's CIP officer. TGIF.

Seriously though, monitoring for CIP exceptions, analyzing wire data of multiple periods (OCC specifically wanted the time period to be longer than a quarter, but FRB was happy with a quarterly review) as well as system data (such as searching for common addresses).

They have also wanted BSA policies and procedures to more clearly differentiate between the use of documentary vs. nondocumentary ID procedures for CIP. We are fairly standard because our CIF system files are used for lending as well as deposit customers. We do have some other banking areas though where this might be a true issue to be addressed.

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