Subsidiaries and BSA

Posted By: PrimeTime

Subsidiaries and BSA - 10/14/15 02:16 PM

Wondering if anyone else has a similar corporate structure that they could provide some insight on. I've seen posts regarding insurance subsidiaries, however nothing regarding investment management companies owned by a bank.

I'm from the bank, which is the majority holder (51%) of both an insurance agency as well as an investment services company. The insurance agency is strictly limited to an agent status of various insurance providers, therefore their BSA requirements are minimized. The investment company provides investment management services to clients.

We currently have a BSA policy/procedures for the bank, and the investment management company that we're the majority owner of has their own, segregated BSA department that we essentially have 0 involvement with. I swear I've seen somewhere the requirements regarding companies that the bank is a 51% or more owner of, however I've been searching all morning and haven't been able to find the source of that information (if it even exists).

Just looking for a little insight as to the bank (holding company)'s responsibility regarding these subsidiaries.

Any responses/PMs would be greatly appreciated!
Posted By: kw004h

Re: Subsidiaries and BSA - 10/14/15 08:48 PM

Perhaps this is a start to what you're looking for? It's not BSA specific, but the link directs you to the OCC guidelines for Heightened Standards .