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#1765787 - 12/11/12 01:57 PM Payroll Cards
Rae Offline
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Rae
Joined: Nov 2003
Posts: 192
We have a business who wants to offer their employees payroll throught prepaid access cards. My FI is considering offering them a product to accomplish this. What are the BSA issues with this product? Do I need to run CIP and OFAC on all of the employees prior to them receiving these cards as most of them will not be current customers of the bank and what monitoring, if any, is required? Any help will be greatly appreciated as this is new territory for me.

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#1765816 - 12/11/12 02:30 PM Re: Payroll Cards Rae
Rae Offline
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Rae
Joined: Nov 2003
Posts: 192
Please, I really need some guidance with this. Just informed about a meeting this afternoon and want to be prepared.

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#1765825 - 12/11/12 02:38 PM Re: Payroll Cards Rae
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,220
Galveston, TX
Read the Electronic Cash — Overview in the BSA/AML examination manual and review Regulation E 1005.18 Requirements for financial institutions offering payroll card accounts.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1765838 - 12/11/12 02:48 PM Re: Payroll Cards Rae
Rae Offline
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Rae
Joined: Nov 2003
Posts: 192
I did all of that prior to posting this thread as I didn't want to waste anyones time. Business is bank customer so no problem there, my question is since the employees are not customers of the bank how much CDD do I need to do on them if any?

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#1765846 - 12/11/12 02:59 PM Re: Payroll Cards Rae
Erl of Baltimore Offline
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Erl of Baltimore
Joined: Jun 2003
Posts: 553
Memorial Stadium
I just finished an overview of BSA issues for the exact same thing. PM me with your email address and I would be more than willing to share it with you.
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signed: The American Public
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#1765902 - 12/11/12 04:07 PM Re: Payroll Cards Rae
Rae Offline
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Rae
Joined: Nov 2003
Posts: 192
Thank you so much, I have already sent my e-mail address to you and am very grateful for your willingness to help me.

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