Thread Starter: Anonymous
Title: Re: Customer is a lender
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Original Anon- Thank you for providing those questions. The FFIEC BSA Examination manual does indicate that banks are not the de facto regulator, but what must we be looking for as far as red flags for this type of business. Are there any reputable resources that I can research and create some kind of framework around this type of customer?
Then one must also consider communications with senior management/board and policy implications. We have NBFIs addressed in our risk assessment which includes mitigating controls of CDD and EDD, ongoing monitoring etc, but would we go as far as letting the board or a committee of the board know that we have a customer of this type? Should board approval be obtained prior to onboarding a customer of this type? My thought is that this is a one-off situation and will not seek additional customers of this type.
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