I recently heard an experienced mortgage banker say that some bank governing body (not sure which one or if it's all of them) advises against keeping an actual copy of a customer's drivers license in the loan portfolio. Instead, we should just be keeping the valuable information from the document in the file. Is this truly valid?
When opening an account for an LLC and the documentation is from another state, do we require special documentation?
We have a customer who has titled his business as an investment company, and indicated that on his CIP form. Recently, he withdrew $15,000 in cash, and when asked the nature of his business, explained that it was "hard-money lending". Considering the amount of cash withdrawn, which is unusual for him, could he be an MSB? What is a hard-money lender?
When a bank has an indirect lending relationship with a car dealer, then how does it go about complying with enhanced due diligence, CIP, etc.?
For an applicant that is not a U.S. citizen, Freddie Mac requires proof of employment authorization from the U.S. Immigration and Naturalization Service. I realize it is a violation of Reg B to keep a copy of a citizen's driver's license in the file but is it a violation to keep a copy of the employment authorization of a green card in the loan file?
I'm having a slight issue regarding BSA/CIP with our loan officers. I'm wondering what other banks may be doing in specific cases. Such as, if the loan is with a corporation, do you identify the corporation and the principals (not as actually responsible for the loan, just as say the president or owner)? What if the president is signing as a guarantor and what if the loan is with an LLC? Of course, with a partnership or as individuals you would identify each person.
What documents are required for our loan files when we do a loan for a Limited Liability Company or a Limited Liability Partnership? Are these considered corporations? Do you have a check list to go by?
We are considering making loans via the internet. I know CIP and internet security need to be arduous. What other considerations and compliance issues are there?
The annual Money Laundering Enforcement Conference co-sponsored by the American Bankers Association and the American Bar Association is always fertile ground for new ideas on BSA program management