The current procedure for commercial loan customers, is to have them complete a risk profile. One of the questions on the profile is asking the customer if they own Privately Owned ATM"s. The risk profile was created by the previous BSA Officer, with the instructions that a risk profile should be completed on the business and on each signer of the loan. While I don't disagree that the risk profile should be completed for each signer and the business, I disagree with her instruction that it is necessary for the customers to be asked if they have Privately Owned ATM's. The title company, that is closing some of our loans says that we are the only bank asking customers to answer that question. Drilling down on CDD and Privately Owned ATM's,has more reference to deposit accounts and Privately Owned ATM.

Welcome to BankersOnline! I'll opine that the title company would have a hard time making that determination. Perhaps other institutions are collecting their due diligence answers a different way in which the title company cannot see. The risks presented by a customer who is money laundering through their privately owned ATMs are just as relevant for loan customers as they are for deposit. As many have stated before, if you don't have the whole relationship, you have no way of monitoring effectively. There are plenty of threads on this site related to privately owned ATMs and the risks they present, I've linked a few recent ones below...

Thread 1

Thread 2

Thread 3

Since you are the only bank asking this question, I would take that as a 'feather in your cap'. I agree with Knowledge above... it is imperative for you to know the types of risks/business offerings/involvement of all your customers, and especially your loan customers.

Don't fear being "the only bank that does something." Fear taking advice from people who have no subject matter expertise, like someone from a title company on AML related due diligence.