We need to refine our list. initially we had SAR subjects, MSBs, ATM owners, non-res aliens, import/export cos, certain businesses for one year and "others" for different reasons. Now we need to go through the list and weed out some...per our regulator.

So, I am looking at some rules of thumb as to why they no longer need to be on the list: So far, a legacy acct is 5 years. Even if they are a non-res, if over 5 years and good, off they go. If dormant non-res, off they go. If 1 year up on some and they've been good, off they go. If the strang trans. that put them on our list no longer done in one year, and acct used as agreed, off they go...any thoughts on this, suggestions based on your annual review process would be welcome. Also, any that you are leaving on forever???

I used a form that I found on BOL to rate the businesses. There were numbers based on the risk for a number of variables (length of customer account history, type of transactions, type of business, etc.) The ending score would then be rated low, medium and high. As long as you document your process and have something to show the examiners, you can lower your rating. I had an examiner tell me to take the low rated businesses off of the list to keep the list current (and manageable).

We have a number rating system & use the similar "no activity in a year & they go" - way of thinking.

We then have a form that shows what we're changing (high to low ... etc ...) & why.

Can anyone tell me where that form on BOL is?

newbsa:

Where are you keeping the form once it is completed?
In the customer file?

The suggested ideas for changing the risk rating are good. One thing to think about is to maintain a record - a list - of changes made. This would be similar to loan risk ratings. Records are kept of downgrades (bad for a loan) and upgrades so that reports can be pulled, trends identified, and so forth. Don't just change the rating - keep track of the changes made.

I would include this data in board reports: how many new medium or high risk by "reason" for change, how many lowered risk ratings and reason for change.

Does anyone have the form with rating system? or just use a spread sheet with comments. ex. No SARs in last 4-5 months?