Hello,

We're in the process of implementing a negative media search. We're looking to screen consumer and commercial deposit relationships after the account has been opened and as BSA does the CIP review.

We do have some questions about the process:

• How do we document negative media searches?
• What parameters do you use for approval/denial of account retention?
• How do you document denials?
• Do we have to worry about UDAAP violations?

Any words of wisdom?

Seems to me pretty much a waste of time for the run of the mill consumer account unless the customer or account exhibits other risk factors.

If you are going to do it and count it as part of your risk assessment (you only do things to mitigate identified risks) then what ever you are doing needs to be fully documentation and retained so that it can be reviewed by auditors or examiners.

Since any number of negative type reports might be uncovered, I think you are going to have a hard time coming up with hard and fast parameters.

You would document an account closure for reason no differently than you would do for any other reason.

Not sure where UDAAP would come in?

Some things we leaned when we implemented this:

1. We tried to run this on all consumer accounts and it was a nightmare. No matter how much we tuned the parameters the volume was too much and the majority were false positives.
2. We settled on private banking customers, commercial accounts (Entities, signers, and beneficial owners), trusts and trustees, and those consumer accounts which alerted.
3. We were using a vendor which allowed us to exports results to a PDF and attached the results to our investigations. For Google searches we converted the results to a PDF and attached to our investigations.
4. I don't believe UDAAP applies here.