High Risk EDD

Posted By: newbie4soul

High Risk EDD - 03/09/17 05:34 PM

Trying to put together a high risk quarterly monitoring EDD and wondering how detailed it should be. Would documenting monthly total amounts only be sufficient with written summary of activities or would a FDIC regulator expect to see a printout of every transaction sorted by transaction type then with total amount, average amount, and deviation %, etc. Someone also mentioned just printing out monthly statements and sign them, which would work if there were only 10 high risk customers or so. In my case, I have almost 50 of them.

Has anyone received any feedback from a regulator about sufficient EDD documentation? Any suggestion would be appreciated.
Thank you,
Posted By: newbie4soul

Re: High Risk EDD - 03/09/17 05:39 PM

Also if it is okay to provide just total monthly amounts but the customer has 5 accounts then would it be okay to provide total amount for all five accounts? Thank you,
Posted By: McFly

Re: High Risk EDD - 03/09/17 05:43 PM

I recommend having an EDD review checklist with different sections for transactional activity (cash in, cash out, wires in, wires out, monetary instruments, RDC, ACH, checks, etc.) The checklist should have a narrative summary describing why the customer's activity is expected, not suspicious, and whether the customer's BSA risk should be changed based on the transactional activity reviewed during the quarter.

I think you should keep the supporting transactional activity documentation in an electronic file for each high-risk customer that can be accessed as needed for regulators, auditors, management, or Board.
Posted By: RockChucker, CAMS

Re: High Risk EDD - 03/09/17 06:48 PM

We also include a section for ATM activity and MSBs. Like JM stated we have a 2 page checklist that is reviewed and the supporting documentation to justify the responses is included.
Posted By: McFly

Re: High Risk EDD - 03/09/17 07:47 PM

Yes - if you have ATM activity, you would have to have some additional sections to expand on the review. My Bank does this for our privately-owned ATMs on a separate form, but you probably could integrate into your EDD review process.

Fortunately, we do not (at the moment) bank MSBs, but would agree with Mr. RockChucker on having a separate MSB questions as well.
Posted By: amillikan

Re: High Risk EDD - 06/01/17 02:26 PM

Would anyone be willing to share their check lists? I am in the process of trying to establish a better review process and I am having trouble finding anything to use as a reference.
Posted By: ItNeverEnds CRCM

Re: High Risk EDD - 06/01/17 06:12 PM

PM me, I don't mind sharing what I created.
Posted By: bhazzard

Re: High Risk EDD - 06/02/17 12:13 PM

We are FDIC regulated and I have composed a EDD checklist that we use quarterly for our high risk customers. We recently wrapped up our exam and the checklist was given compliments from our examiner. I do not mind sharing just PM me!