My Upper Mgt does not want to add another form at account opening for non-personal accounts. However we do not currently have a way to determine expected account transaction type or volume. We use Patriot Officer which has a CIP screen where you can load "estimated transaction detail" information that is then used by the system to tell you when a customer deviates from what is "estimated or norm?.

We are thinking of mailing a profile form to all customers who are considered a "higher rish" which may be most of our non-personal customers.

Does anyone else try to obtain this information after account opening versus at account opening ? If so, what percentage of the forms are returned by customers? Also, do you have an example of a letter you use to mail with the profile forms that you do not mind sharing ?

Thank you. NOTE: This way is not my preference but at this point my hands are tied somewhat.

We do it at account opening.

We do it at account opening as required in our CIP.

I'll be the first, but probably not the last, to predict that your return rate on these mailed questionaires would be very low. As a small businessman, I assure you I would not take the time to do it... My partner would, but she would just make stuff up.

You might try a test before you move to this method.

As for your regulator's opinion, as always, it depends on who walks through the door. If the EIC believes BSA is important and understands the current philosophy, he or she is going to say this technique is doesn't even reflect a good faith attempt to get the information you need to identify high risk customers.

Anyone who's ever manned a new accounts desk knows that the only day you are in charge of the relationship is the day the account is opened. Trying to get information later is a wasted effort.

We do it at account opening. Ken is right, you only have their attention on that day.

We mailed questionaires to our old accounts when CIP came into being. Out of all that we mailed, we probably didn't get 25 of them back.

We had to go to Plan B which was to review the business accounts individually ourselves. What a pain!

BSA Dixie Queen,
Have you looked into revamping the forms that your account opening reps are using rather than adding a new form? When my bank when through the process of developing our commerical customer form we discovered that the branch staff was sort of already asking the questions about anticipated levels when they were helping the new customers pick out the best account that fit their activity. The branches were even recording this info on a customer profile sheet, all we did was change the phrasing a little to fit what we need for AML purposes, too. Very little training was needed since the branches were already familiar with the form.

To make it easier on branch staff, they need to be shown that asking these questions of their customers can be beneficial to the customer, too (by putting them in the right account, cross-selling, etc), and that it's not just the mean old compliance people making their lives more difficult!!