Ok I just printed this 77 page rule and wanted to see if anyone has had the time to read through the whole thing and digest the important points.

From a quick overview it appears that there is nothing we are to do with the Appendix A unless we are contacted by FinCEN.

Is that correct?

Correct. This is a sleeper reg that gets activated if FinCEN contacts you for information.

Would you recommend we put any kind of mention in our Correspondent Banking policy concerning this? Maybe who would be responsible for responding if contacted or just as a paragraph to let regulators know we have read and are familiar with it?

I am thinking of the CYA part of BSA.

Excellent idea to add it to your CB policy, particularly if you do anything with foreign banks.

When it comes to BSA, CIP and AML, it's always PC to CYA.

Thanks John. We do quite a bit of correspoondent banking so I think I will add something so the regulators know we are on top of it.