I'm looking for feedback about loans:

For a branch office, do you post the Patriot Act Notice (gathering information/Identification on new customers) in every loan officers office -- or just one in that area of the branch?

We have the notices on the lobby desks new acct / loan assistant / etc & do not have the notices in any offices.

We have them in every office that has customer interaction- new accounts, loans etc

We also have the notices in the lobby, on all CSR's desks and on all loan staff's (secs & officers) desks.

Just as a reminder, the requirement is to give it or place it so it is reasonably seen by the customer. If you have a sign in sheet or something, that central location would reduce maintenance and inventory as well as take up less wall/desk space.

FED-REGS, BANK-COMPLIANCE, 31 CFR §103.121(b)(5)

(ii) Adequate notice. Notice is adequate if the bank generally describes the identification requirements of this section and provides the notice in a manner reasonably designed to ensure that a customer is able to view the notice, or is otherwise given notice, before opening an account. For example, depending upon the manner in which the account is opened, a bank may post a notice in the lobby or on its website, include the notice on its account applications, or use any other form of written or oral notice.

During our exam, we were counseled to have notices seemingly EVERYWHERE (each desk and common area). Not only should they be everywhere, but they should contain the model language provided.

Are there any restrictions on the size of the sign? We have an 8.5 x 11 frame that we put 2 disclosures in - side by side. Is that acceptable?

That's what we're using and the examiners did not seem to have a problem with it.

Wonderful! Thanks.

As far as Lending goes, we send the USAPA Notice out to the Borrowers with the initial loan disclosures. Not all Borrowers actually come into the Office.

We have a Mortgage Company as an Affiliate that operates out of a separate office from the Main Branch. They don't originate or close any loans in their name...they broker out all loans they bring in. Is it necessary to have the Patriot Act Notice displayed in their office? Thanks.