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#625748 - 10/17/06 03:51 PM 314a query?
Simply Sheldon Offline
Diamond Poster
Simply Sheldon
Joined: Oct 2005
Posts: 2,047
S.E. TX
I think I've read somewhere or I've heard at a seminar or something that the Security Officer should run the 314a query. This is something that our Security Officer has been doing for years and we'd like to move it over to the BSA Officer's responsibilities. That's ok right?

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#625749 - 10/17/06 04:26 PM Re: 314a query?
LauraL Offline
Gold Star
Joined: Jun 2005
Posts: 365
Georgia
I am the BSA officer and I conduct the 314(a) searches. We've never had any examiner say it wasn't okay.
_________________________
"I'd rather be running a marathon than doing compliance!"

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#625750 - 10/17/06 04:50 PM Re: 314a query?
Dip Offline
Power Poster
Dip
Joined: Mar 2005
Posts: 6,298
San Diego, CA
314(a) is super-confidential, so I wouldn't have just any employee do it. I think it is fine to have the Security Officer do it, but I would have it be a dual process.

Here's what we do. The Central Ops Manager (also the Security Officer) and I (BSA and Compliance Officer) receive the FinCEN emails. Central Ops Manager checks the list, then writes Positive/negative on the front page with his initials and the date. Then I get the list, doa spot check of some of the names, then initial and date the front page. We only retain the front page of the list as evidence. I personally walk the remaining pages to the shred bin.
_________________________
Dabbling in banking, law, accounting...the life of a trustee.

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#625751 - 10/17/06 05:04 PM Re: 314a query?
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
It's part of BSA, but there has been no regulatory expression of preference for who does the searches. In many banks it's a purely clerical function.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#625752 - 10/17/06 06:27 PM Re: 314a query?
Simply Sheldon Offline
Diamond Poster
Simply Sheldon
Joined: Oct 2005
Posts: 2,047
S.E. TX
I appreciate all the input. I understand how important the list is and I always thought this was supposed to be like this for a dual control reason. I, as compliance officer, already check behind them (we do it all in the Patriot Officer Software)as reviewed.

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