Does the part (6)records of accounts to purchase, sell, lend, hold, or maintain custody of securities include having our bank employee who sells through UVEST to check their records?

I'm not sure what UVEST is, but it sounds to me like it deals with investments and that he is probably a broker. If that is the case, yes you need to have that employee check his client list per the requirements.

I think it in depends on the type of relationship you have with UVEST. If the accounts are "owned" by UVEST as opposed to only being "cleared through". Then I'm guessing that UVEST is responsible.

Check your contract with UVEST. I'd also recommend checking with your counsel for their opinion.

If you don't want to take those steps, then your only alternative is to fulfill the 314(a) request as though your organization were responsible for those accounts as well.

I'm thinking that the sales and purchases would be cleared through UVEST Financial Services. It's a partnership arrangement of sorts with this company something like Raymond James, etc.. Anybody else care to weigh in?

Does anyone have the Q&A put out by FinCen re 314a requests (or know where I can get a copy)?

Post deleted by NCAA nut

Let's keep in mind that the reason FinCEN pulled the Q&As from their website is to keep them out of the hands of the bad guys as much as possible. I'd recommend that you NOT send the Q&As to someone you don't know. Direct them to contact FinCEN, who I'm sure can provide the Q&As if there is a legitimate need for that person to have them.

Good point! Thank you!

The OCC emailed them to the bank contact the day before the info requests were sent. So all OCC banks should have them!

Thanks anyway. I found them on the internet.