Relative to BSA/AML, is there anything within FFIEC guidelines, or anything else for that matter, that states a bank must get the purpose for a wire/funds transfer? At a previous institution that I worked at we were cited by the OTS because we were not obtaining the purpose for a wire transfer. I have spoken to other colleagues and they, too have been cited; however, no one can find where this is an actual BSA requirement.
Where can I find some detailed information on e-banking?
Under the updated FFIEC guidance for online banking environments, are individuals operating DBA's that do not engage in high risk transactions, such as ACH/Wire origination, required to have the same layers of security as larger commercial accounts? The guidance seems to suggest that all commercial accounts require enhanced security. However, most of the small DBA's function as individuals with limited online banking activity.
When exempting a Phase II non-listed business, at what point can the exemption form be filed? Should it be filed after the 5th CTR is filed (when the 6th reportable transaction occurs) or can it be filed in lieu of the 5th CTR?
What is your opinion on the risks associated with allowing consumers (individuals or non-businesses) to use remote deposit capture services?
Our external auditor has requested that we create a firewall policy. I certainly wouldn't know where to begin. Does anybody have or know where I can get a template for a firewall policy?
When a loan is secured by two properties, which one do I list on the LAR? A customer's existing home and the home he is purchasing are being used to secure the loan.
The independent auditor who completed our BSA compliance review suggested that our bank should find a way to include customer ATM withdrawals when aggregating cash-out transactions for CTR purposes. Most of our customer ATM activity is at other banks' machines, because we only have two ATMs ourselves. Should be include withdrawals made at those other banks' machines, even though we didn't pay out the cash ourselves?
I've been in banking for many years and cannot recall ever having a church on the exempt list for CTR filing. I have a branch requesting that their local church be considered. I am unable to find anything in the FFIEC Manual stating specifically that we cannot, but for some reason I don't feel right about it. Are you able to provide me some guidance?