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#1623918 - 11/03/11 02:30 PM Exempt Customers
newbietoo Offline
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Joined: Aug 2009
Posts: 201
Do exempt customers require board approval?

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BSA/AML/CIP/OFAC Forum
#1623954 - 11/03/11 03:22 PM Re: Exempt Customers newbietoo
cbinder63 Offline

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cbinder63
Joined: Dec 2001
Posts: 674
Colorado
No, unless your BSA Policy/Program should include that as a step.
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#1624063 - 11/03/11 04:41 PM Re: Exempt Customers cbinder63
P*Q Offline

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Joined: May 2001
Posts: 8,458
Somewhere
I include my exemptions in my risk assessment by choice. That is reviewed annually by them.

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#1624101 - 11/03/11 05:30 PM Re: Exempt Customers newbietoo
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Listing in risk assessment is reasonable. Having the board approve them is an upward delegation of responsibility.

How would a board member know whether to vote "Yes" or "No?"
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1624109 - 11/03/11 05:39 PM Re: Exempt Customers Elwood P. Dowd
Princess Romeo Offline

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Where the heart is
Please don't give examiners any ideas here folks!
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Regulations are a poor substitute for ethics.
Just sayin'

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#1624137 - 11/03/11 06:13 PM Re: Exempt Customers Princess Romeo
newbietoo Offline
100 Club
Joined: Aug 2009
Posts: 201
Thanks for the responses. We had not done this before, so I just wanted to get some feedback to make sure we weren't missing something.

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#1624224 - 11/03/11 07:19 PM Re: Exempt Customers newbietoo
P*Q Offline

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Posts: 8,458
Somewhere
Agreed, didn't say they "approve" the exemptions or the risk assessment, they only review the assessment so they're aware of our risks since they hold fiduciary responsibility. That's all. smile

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