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#82606 - 05/23/03 07:32 PM BSA Exam
DebbieC Offline
Member
Joined: Jul 2001
Posts: 66
Owensboro, KY USA
I'm looking forward to an OCC exam for BSA in July...anyone been through one lately that would be willing to share some hints for the hot points. I expect they are the usual.

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#82607 - 05/23/03 07:35 PM Re: BSA Exam
RVFlyboy Offline
Power Poster
RVFlyboy
Joined: Oct 2000
Posts: 5,984
Soaring over Georgia
Why are you looking forward to it - are you a masochist?
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#82608 - 05/23/03 07:52 PM Re: BSA Exam
complyguy Offline
Gold Star
complyguy
Joined: May 2001
Posts: 494
PA
Put on your asbestos clothes - they're breathin' fire.

We made some major strides in the last two years, and had just begun to see the first fruits of our AML upgrade - NOT GOOD ENOUGH!!!

IMHO, they came in with an agenda of where they want all banks to be, REGARDLESS of size, product offering, complexity, etc., and that's what they demand. I'm still livid.

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#82609 - 05/23/03 07:56 PM Re: BSA Exam
JenniferK Offline
New Poster
JenniferK
Joined: Jun 2002
Posts: 10
Debbie, I went through an OCC BSA exam in March 2003. They focused on suspicious activity and your money laundering detection processes. Major items that seemed different from the last exam which we had in January 2001:
1) They sent me a list of customers (about 15) prior to the examination. They wanted copies of sig cards, 3 months' bank statements and copies of the entire transactions for their 3 largest debits and 3 largest credits. They pulled this list of customers from the CTRs and SARs we had filed. They looked very closely at this information. I had to provide as much detail as the branches could tell me about the larger cash transacations and wire activity of the customers.
2) They focused on wire activity and how we were reviewing it for suspicious activity, and especially the wires to and from non-cooperative countries.
3) They did not focus on what we were obtaining at account opening to identify customers, since they knew it would be changing with the finalization of CIP.

Those are the main items that I can remember.

Good luck. If you have any specific questions, I would be happy to try to answer.



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#82610 - 05/27/03 01:57 PM Re: BSA Exam
I Wear Many Hats Offline
Platinum Poster
I Wear Many Hats
Joined: Mar 2001
Posts: 591
the beautiful state of ME
I have been through a few OCC BSA exams and a lot depends on how much time and staff they have. We have an exam the week of the 9th and the request list I received asks for policy, recent audits, exemption back-up, SARs and back-up and the usual logs, access to CTRs, etc. They did not request a lot and plan to have our entire compliance exam complete in two weeks.
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The paradox of planning is nothing happens....

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#82611 - 05/27/03 04:11 PM Re: BSA Exam
Lestie G Offline

Power Poster
Joined: May 2002
Posts: 3,607
Near the Land of Enchantment
They're looking for BSA compliance in all exam areas (i.e. Trust, safety and soundness areas, etc.)
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Opinions my own.

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