314(a)-I think I'm searching deeper than required!

Posted By: P*Q

314(a)-I think I'm searching deeper than required! - 03/19/03 08:02 PM

After rereading the FAQ'a about 314(a) requests, I've had my branch staffs looking up safe deposit records which are NOT electronic, they're looking up paper manually. According to the FAQ is states safe deposit only has to be searched if records are electronic. Also, monetary instrument logs and wire transfer logs are both manual and I've been searching for the past year. FAQ states if the transaction is not linked to an account, only previous 6 months are to be searched. Am I crazy, am I understanding the FAQ's correctly???? Help!
Posted By: BrendaC

Re: 314(a)-I think I'm searching deeper than required! - 03/19/03 08:08 PM

The monetary instrument records are only those we keep under the BSA $3000 rule. That change has significantly reduced as search efforts in that area. If you don't keep your safe deposit box records on an electronic system, I don't think you have to check them at all.

FAQ: (8) safe deposit box records to determine whether a named subject maintains or maintained, or has or had authorized access to, a safe deposit box, but only if such safe deposit box records are searchable electronically.

Your search of the records described above need only encompass current accounts and accounts maintained by a named subject during the preceding twelve (12) months, and transactions not linked to an account conducted by a named subject during the preceding six (6) months. Any record described above that is not maintained in electronic form need only be searched if it is required to be kept under federal law or regulation
Posted By: Anonymous

Re: 314(a)-I think I'm searching deeper than required! - 03/19/03 08:09 PM

I understand it the same way you are thinking after reading the FAQs (check prior 6 months and safedeposit box only if electronic records)
Posted By: BrendaC

Re: 314(a)-I think I'm searching deeper than required! - 03/19/03 08:11 PM

By the way, we went back through our monetary instrument records and made a list of noncustomers. Since we primarily sell monetary instruments, $3000-$10,000 in cash, to customers, we have only identified five individuals we need to worry about verifying to the FinCEN research requests.
Posted By: CalifDreamin

Re: 314(a)-I think I'm searching deeper than required! - 03/19/03 08:13 PM

Which sounds like (unfortunately) that I am reading correctly that if we have a request where we are to search back to 1994, that includes our monetary instrument logs and wires even if they are not electronic. Yes?