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#945431 - 04/18/08 02:12 PM BSA risk assessment form.
FrankB Offline
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Joined: Apr 2007
Posts: 13
We live in a rural community. Many of our customers do not have physical addresses and use PO Boxes. Here's my question: Once we have verified an individual through a proper ID, such as drivers license, and opened an account do we have to put a physical address on the BSA risk assessment form.

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#945563 - 04/18/08 03:20 PM Re: BSA risk assessment form. FrankB
80's Lady Offline
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Joined: Apr 2007
Posts: 295
I think you should review your procedures to see what they say. I'm assuming that the Risk Assessment Form you are speaking of is an internal form? It is ok to have a mailing address and a physical address for a customer, but you must obtain a physical address. Where you document that is up to what your procedures say and what your systems will allow.
I use to think I was a smart cookie before I started working in Compliance. Now, I have mastered the art of the blank stare!

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#945676 - 04/18/08 04:05 PM Re: BSA risk assessment form. 80's Lady
Deena Offline
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Joined: Nov 2000
Posts: 2,701
Also, keep in mind that CIP requires you to get a physical address, even if it's for a next of kin (unless they have an APO or FPO).
Opinions expressed are mine and not necessarily those of my employer.

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#945696 - 04/18/08 04:25 PM Re: BSA risk assessment form. Deena
WreckEmTech Offline
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Joined: Feb 2008
Posts: 154
A description of where the customer lives will also suffice if no physical address is available. For example, "4.5 miles west of town, turn right on County Road ###. Second house on the left."
You have to know where to find your customer, not their mail, which is the reasoning behind the physical address requirement.
Check your institution's procedures for information on where to document it.

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