I was on vacation when the information pertaining to the "Joint Agency Request Relating to Information Pertaining to the Terrorist Attacks" was released. The deadline to sign up for the "Control List" was October 12 so I missed it. I would still like to read the release and possibly still try to sign up to receive the list, but I can not locate the "release" stating where to submit the name of the person to receive the information. Does anyone have the location of the "release letter"? Thanks for your help.

You can get more information about the Control List here.

Here's the interagency letter in a Word doc.

If your primary regulator is the OCC, here is their version (in ascii text, so it will load fine on any browser.

If your primary regulator is OTS, they have a pdf version of the letter on their site here.

The FDIC already has bank email addresses, so they are contacting banks individually, as we understand it, rather than sending out this letter.

Our regulators are FDIC and I haven't received any information yet.

Are there any other FDIC institutions that have received this info....

Your answer may be in the 10-11 thread about the control list.

Also, I have received an email back stating that the control list will be sent to me shortly. I assume by email.

Got the control list! There are over 150 names and "also known as" on the list with no automated process for checking. It's going to be fund to check manually.!

This is to bwest. Hope you read this again. Who is your regulator? And do you have any ideas on how you will be checking your list manually? Thanks

Marie, it's the Federal Reserve and the only way I can determine to check is manually one-on-one to customer identification files, wire transfer files, ACH files, etc. Also, if your records go back as far as January 1996 they want you to look back that far.

If anyone finds a way to do it any differently, please share it with the rest of us. Thanks

Bwest - unfortunately, I think I'm in the same box you are. If your processing system doesn't capture / retain information from wire transfer customers, ACH customers, cashiers check purchasers, etc., then you need to go to each area & check manually. This is a massive undertaking.

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I am assigning out duties to department heads on a "need to know" basis. There is no way I as the only compliance person can handle this along with all the other duties I am faced with.

To bwest, How do you get away with assigning out duties? Management tells me I am not allowed to utilize their people's time. I am being sincere. How were you able to accomplish this without upsetting your Management team? It would sure make my life alot easier.

I also received my list today. It is long and research for 5 years. I am not sure how I will handle it yet. I will think about it next week. We have a conversion this weekend and I have to work all weekend, so this one can wait. I don't think wires, ACH, and cashier checks will be too difficult since we all maintain pretty good records for BSA. Loans, new accounts, and internal transfers maybe more difficult.

Thanks for your help and responses.

Maria- Your bank is in deep trouble if your business managers disclaim responsibility for regulatory compliance related to their units. Compliance is everyone's business--especially those who create and sell regulated products. If business managers are allowed to ignore the cost and inconvenience of regulations, they are encouraged to take undue risks. You and the bank will eventually pay the price.

My head is still spinning over the control list. For a large Bank, this is an over-whelming task. I cannot imagine manually checking for all these names, in each area, for the time frames required. Please someone tell me it is only a bad dream. I agree with bwest that each department will have to take an active role in the process. Are the names on the control list also included on the OFAC list? I'm interested in knowing how other Banks will manage this task.

Maria, I would think that all loans, as well as other accounts, should come under the customer's identification file. Can you not just do a manual search for any CIF under those names. Now checking wires, cashier's checks, etc. may be a little more difficult. I have assigned out the duties of checking those, however, I will follow up very closely since I have been the named contact.

Were you the assigned contact at your bank?

Yes, I am the contact person here. And when I am responsible for something, I too take it personally like you all do. So I would appreciate help from employees to accomplish tasks, but I would monitor and give direction to the best of my ability. But it does not always work that way as I am sure you all know. I seem to have to complete the tasks within my department. There are two of us. We had three but the department was cut-back. I am not complaining, not really, I just know we could accomplish so much more so much faster if (some) of my Management would realize that compliance and audit is everyone's job. Everyone should be accountable for their part. The other bank's I worked for in the past operated that way. This is our first year having this department. I am hoping, in time, I can change the thought process. Enough about that.

As for the "Control List" I do believe I will try the CIF list first. Only trouble is I do not believe it goes out for 5 years. Any other ideas?

Thanks for listening and for your ideas!

The instructions make a statement that they realize it may not be feasible for some institutions to go back for 5 years and that law inforcement requests that those institutions who can easily go back that far do so.

Hey, there is only one of me so I do sympathize with you. I came from a $750,000 million institution with many branches and subsiduaries where I had to wear the compliance hat along with a few more hats! I am very very happy that at this smaller bank I am expected to handle just compliance. From my experience I think Management looks at Compliance as a expense burden. We don't make the bank any money but they have a difficult time seeing that we can save the bank big bucks by keeping them out of regulatory trouble. Oh well, we compliance people get little respect!

Keep your chin up Maria!!

The Joint Agency Request for a contact person was only from FRB, OCC & NCUA. Has anyone with a State Non-Member (FDIC) Bank, an OTS bank or a State Credit Union received any information about the Control List from their regulator?

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Al Miller, CRCM
Fremont Bank (CA)
(510) 790-5825
(510) 505-5211 FAX

Opinions expressed are my own and not necessarily shared by my employer.

Yes, we are an FDIC state non-member bank. I received the list via e-mail on 10-19-01.

We're an OTS regulated institution. They actually posted before anyone on October 5th, there's a CEO letter on the website. We received an advance phone call and the formal notice from them, provided the contact person and as of today haven't heard anything. Yesterday I left a message for the compliance person at OTS SF to see if they had any indication as to when we should expect the list. As of yet, I haven't heard from the OTS.

Has any other OTS insitution received the list?

Maria & bwest,
I, too need a hatrack in my office for all the hats I wear. For example, I'm not the contact person, but I'm the one who checks e-mails every day for compliance alerts and things that require time-sensitive responses. So I had to print out the need-to-know list, give it to the contact person, then tell him he has to kill me. Fortunately, since I'm in compliance, he's ignoring me.

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Complyguy,
That was funny! If anyone realized how much time we spend looking and reading each other's questions and answers, they would probably kill us all! But for a newcomer to Compliance, I have found BankerThreads so helpful! Even when I do not know the answer to help someone else, I read the question and then try to look it up myself. Then I go back in to see what everyone has answered. I am hoping in time this will help me learn how and where to find my own answers. Plus it is so great knowing other people have the same experiences as I do. We learn from each other and help each other. I thank you all for your past and future knowledge and hope I can someday do the same.

Dear, about the time you think you know the answers or where to look for them everything will have changed and there will be a all new set of answers.

We just received our "Control List" via e-mail from the OTS today. Would appreciate any advice, suggestions, words of wisdom, etc. from those of you who were so fortunate as to receive this list much earlier about how you handled this project. Thanks.

I just got the email from the OTS on our list, but was unable to open the word and excel file attached? Did anyone else have problems opening the attachments?

Also see the thread "Control List & FDIC Deliver" 10-26-01