exam fun: DL info on BO forms

Posted By: Anonymous

exam fun: DL info on BO forms - 07/09/21 06:33 PM

What's frustrating to me is when a regulatory agency designs a form that seems as though it was intentionally crafted to cause exam problems. They failed to require banks to record the driver's license information or any other record of how we verified the identity of a beneficial owner, on the BO forms, yet, when we are examined, we have to prove that we either viewed a driver's license or otherwise verified the identity of each individual, including ones who are not present.

Have any of you redesigned the (terrible) BO form put out by regulators, so as to capture this info directly on the form? This seems like it would make exam experiences a little easier, possibly, unless stupid things would happen like someone writing "existing customer" or an expired DL date on the form.
Posted By: SmallBankBSA

Re: exam fun: DL info on BO forms - 07/09/21 07:41 PM

Yes, we use a form that we created that captures the DL information for the beneficial owner and control owner directly on the form itself.
This form has been through internal audits and regulatory exams with no issues.
Posted By: Anonymous

Re: exam fun: DL info on BO forms - 07/09/21 11:04 PM

Have you had to produce copies of IDs for your exams anyway, or did auditors accept your form's record as proof?
Posted By: Cbigun

Re: exam fun: DL info on BO forms - 07/12/21 01:51 PM

We just had a BSA Exam and our form is provided by our core which does have the information documented on the form. They did not ask for a proof of the DL, even though we did have them.