Thread Options
|
#1295262 - 11/30/09 12:59 PM
Re: Internet Gambling
MagicCity
|
10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
|
Now we will see if Congress can figure out what it wants to do with this fiasco.
_________________________
John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
|
Return to Top
|
|
|
|
#1295271 - 11/30/09 01:53 PM
Re: Internet Gambling
Princess Romeo
|
Platinum Poster
Joined: Feb 2003
Posts: 962
PA
|
Well nice - now that everyone has already expended resources to send Reg GG notices to their commercial accounts before the initial 12/1/2009 deadline.
Between this and the "oops we didn't intend for the 21 day rule to cover ALL open-end accounts", it's going to be harder and harder to convince management to spend money to comply by these deadline dates.
ETA: Thanks for the heads-up Retread! I totally agree!! I have nothing nice to say right now, so I'll keep my mouth shut.
|
Return to Top
|
|
|
|
#1295333 - 11/30/09 03:27 PM
Re: Internet Gambling
ForceFull1
|
10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
|
Although compliance with Reg GG is now optional until 6/1/2010, it's a good bet (yes, I know that pun's been used before) that Congress will do something with UIGEA between now and then. If you've started blocking authorizations for card-not-present gambling merchant transactions, I suggest you consider continuing to do so. If you have started vetting new business accounts to identify those that might have a higher risk of being involved in Internet gambling (legal or illegal), it might be a good idea to continue that, too, since it could be an indicator of higher risk for money laundering or other suspicious activity.
It could actually be a good thing to have a policy on whether you'll accept business accounts that involve Internet gambling, with or without UIGEA.
Then watch for developments in the coming months.
_________________________
John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
|
Return to Top
|
|
|
|
#1295336 - 11/30/09 03:29 PM
Re: Internet Gambling
John Burnett
|
10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
|
If you haven't yet notified your commercial customers of Reg GG compliance requirements, and haven't incorporated that notification and/or certification into your account documents/signature cards, delay any action on those items.
_________________________
John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
|
Return to Top
|
|
|
|
#1295341 - 11/30/09 03:34 PM
Re: Internet Gambling
ForceFull1
|
Power Poster
Joined: Oct 2009
Posts: 3,927
|
Since we have the policy approved by the Board already, we'll keep it in place. We'll also keep the Due Diligence part in place as well. If and when Congress/Regulators change anything we'll adapt at that time.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius
|
Return to Top
|
|
|
|
#1295358 - 11/30/09 03:52 PM
Re: Internet Gambling
Doug Hendrickson
|
Platinum Poster
Joined: Feb 2003
Posts: 962
PA
|
Since we have the policy approved by the Board already, we'll keep it in place. We'll also keep the Due Diligence part in place as well. If and when Congress/Regulators change anything we'll adapt at that time. We are doing the same.
|
Return to Top
|
|
|
|
#1295497 - 11/30/09 05:49 PM
Re: Internet Gambling
MagicCity
|
10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
|
Magic City, You must be talking about a different "Ken;" I did not call this one. My only acknowledgement to the possibility of delay was to suggest that banks word their policies and procedures to take effect on the actual effective date of the regulation, "as amended" without mentioning December 1, 2010. The conclusion that banks need more time to prepare is refined cynicism. The only banks that need more time are those that made no effort. Since their gamble paid off this time, they will roll the dice again. Bad precedent...
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
|
Return to Top
|
|
|
|
#1295762 - 11/30/09 09:08 PM
Re: Internet Gambling
Elwood P. Dowd
|
Platinum Poster
Joined: Nov 2005
Posts: 568
Texas
|
Ken I really appreciate the wording you had suggested for the policy effective date because being proactive, we completed everything as required to meet the effective date. Since our policy has an no actual effective date, we are good whenever or if it goes into effect. Once again, you saved me time and trouble with your suggestion.
Thanks!
|
Return to Top
|
|
|
|
#1296612 - 12/01/09 09:10 PM
Re: Internet Gambling
NewTooBSA
|
Diamond Poster
Joined: Aug 2003
Posts: 1,357
A Grant Wood painting.
|
Reg GG should have no effect on the good folks raisng horses and dogs for racing. Should it?
_________________________
The opinions expressed are what you can expect for the price paid.
|
Return to Top
|
|
|
|
#1296645 - 12/01/09 09:44 PM
Re: Internet Gambling
Inquisitor / Sommelier Omega
|
Junior Member
Joined: Sep 2005
Posts: 40
|
If we have added this to our BSA policy:
On December 1, 2009, rules to implement the Unlawful Gambling Enforcement Act of 2006 (UIGEA) will be in effect. BANK has adopted the following procedures to comply with these rules in the areas of debit card transactions and new accounts opened for commercial entities.
What do you suggest we do?
|
Return to Top
|
|
|
|
#1296660 - 12/01/09 10:01 PM
Re: Internet Gambling
burgh
|
10K Club
Joined: Jul 2001
Posts: 83,364
Galveston, TX
|
Omega - no effect, unless they are also operating an on-line bookmaking operation.
burgh - the law is still effective, the mandatory compliance date has just been postponed.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com
|
Return to Top
|
|
|
|
#1296680 - 12/01/09 10:18 PM
Re: Internet Gambling
rlcarey
|
Power Poster
Joined: Jun 2001
Posts: 8,272
Where the heart is
|
I wonder where this will leave TVG? www.tvgnetwork.comThey operate a website to accept bets for horseracing under separate state licenses. Presumably, they give each state a cut of the action just like they do at the track.
_________________________
CRCM,CAMS Regulations are a poor substitute for ethics. Just sayin'
|
Return to Top
|
|
|
|
|
|