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#2078070 - 05/11/16 02:24 PM Out of State Gaming Facility
Livin' the Dream Offline
Junior Member
Joined: Feb 2015
Posts: 33
Up a creek...
We have purchased a participation loan with an out of state gaming facility, we are in Ohio and the facility is in West Virginia. They own and manage gaming machines and are granted the authority by the West Virginia State Lottery Commission. They are permitted by the Commission for each machine in use and the retailer in which the machine sits is also licensed with the Lottery Commission. Does this require enhanced due diligence and should it be considered a high risk account? Are there any measures, above and beyond the norm, this account would require? This is a new situation for me.

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#2079613 - 05/20/16 03:36 PM Re: Out of State Gaming Facility Livin' the Dream
Livin' the Dream Offline
Junior Member
Joined: Feb 2015
Posts: 33
Up a creek...
Bump

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#2079668 - 05/20/16 06:35 PM Re: Out of State Gaming Facility Livin' the Dream
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,700
The Country
I don't believe there is a blanket answer for your question. These situations are very fact dependent. Because it is a new type of business for the bank, it would be beneficial for someone to watch the account until you become familiar and comfortable with the types of transactions and volume. If you cannot get comfortable with the transactions I would make sure I continue to watch them and file as necessary. Another thing to consider is how they are getting paid and being paid. Selling/running gaming machines is not illegal so there is a good chance you may be able to get comfortable with the business enity and transactions and not have to perform ongoing EDD.
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A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
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#2079674 - 05/20/16 06:47 PM Re: Out of State Gaming Facility Livin' the Dream
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Pretty unusual situation, one that suggests you should have been consulted before the loan was purchased. In your shoes, I would call the BSA officer at the bank that sold us the loan and go fishing...
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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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#2079744 - 05/21/16 12:33 AM Re: Out of State Gaming Facility Livin' the Dream
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
You mentioned that you purchased a participation in the loan. Is your bank doing the servicing for the loan, or do you just receive proceeds from the lead lender as payments are made? The amount of due diligence may depend on the level of engagement you will have with the loan.
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Regulations are a poor substitute for ethics.
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#2079771 - 05/23/16 12:23 PM Re: Out of State Gaming Facility Princess Romeo
Livin' the Dream Offline
Junior Member
Joined: Feb 2015
Posts: 33
Up a creek...
The lead bank does the servicing....

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#2080631 - 05/26/16 04:07 PM Re: Out of State Gaming Facility Livin' the Dream
Livin' the Dream Offline
Junior Member
Joined: Feb 2015
Posts: 33
Up a creek...
Thank you all for the thoughts, it is appreciated!
Last edited by Livin' the Dream; 05/26/16 04:08 PM.
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