Bank Risk Assessment - Geographic Areas

We have included branches that are in HIDTA's (none in HIFCA) in our assessment area. We take that into consideration for suspicious activity. However, are banks required to know exactly how many customers reside in a HIDTA for the risk assessment? Half of the banks assessment area is classified as an HIDTA.

We always use BSD for our risk assessment. For jurisdictions, this includes the number of clients and transactions (Counts and Amounts by transaction type) to help support our conclusions.

There is not a requirement that you know how many customers are in a HIDTA. It may be useful for your risk assessment, but it's not something we collect. In the geographic portion of your risk assessment if you were to cover what portion of your bank is in the high-risk area and describe how you consider it for suspicious activity to mitigate the risk.

The more data, the better, of course, so if beyond the number of branches you have access to the percentage of customers or deposits or whatever, that's all additive, but my examiners like our risk assessment and I don't have that.

ACB, what's BSD?

When in doubt check the guidelines

https://bsaaml.ffiec.gov/manual/Appendices/11

Low

The bank is not located in a High Intensity Drug Trafficking Area (HIDTA) 305 or High Intensity Financial Crime Area (HIFCA). No fund transfers or account relationships involve HIDTAs or HIFCAs.

Medium

The bank is located in an HIDTA or an HIFCA. Bank has some fund transfers or account relationships that involve HIDTAs or HIFCAs.

High

Bank is located in an HIDTA and an HIFCA. A large number of fund transfers or account relationships involve HIDTAs or HIFCAs.

While the exact number of customers in HIDTA is not required (It would be good to have that data), you would need to know about the HIDTA/HIFCA location for funds transfer transactions based upon above.

Colorado - BSD is Bank Specific Data. Our regulators would never agree with our conclusions in our risk assessment if they weren't supported by Bank Specific Data (Numbers of customers, count/amount per product services, jurisdictions we do business with, number of CTRs and SARs filed, etc.).

Everyone one of our locations is in a HITDA area, so all customers are.