Originally, you wrote your CIP in 2003. Is it time to change?
If you have any of the questions below, we will explore changing
your CIP in light of new systems, processes and technology in
2018.
Your program should shift with the new technologies and
identifications in the market place. This program will look
line-by-line at the regulation and point out avenues of change
to explore in 2018.
If there is an elephant in the room it is Customer Due
Diligence. What does it mean to “know” your account holder? When
do we have to ask purpose, source and anticipated volume
questions? How can we enforce compliance with our program in our
institutions?
These questions are hard ones and the regulation on CDD
doesn’t help. This program will evaluate CDD and EDD regulation,
exam guidance and provide thoughts on how to proceed with a
program that is sales friendly to the account holder. We look at
the regulation line-by-line and what to expect during
examination.
Covered Topics:
- Line by line look at the regulation on Customer
Identification Programs
- What Information that must be obtained before an
account is opened
- Required Documentary and non-documentary
verification
- Should we add more types of identification? What
types are available?
- Do we keep CIP up to date?
- How should we address online banking?
- Is non-documentary verification enough?
- Can we back off from our CIP of 2003 now that we
have more systems in place?
- Examination expectations on Customer Due Diligence
- Keeping customer records up to date
- Anticipating transactions and activities
- Enhanced due diligence on high risk customers
- Developing the questionnaire
- On-going during the relationship
- When should we close a relationship? And how do we
close?
- What regulatory concerns do we have?
- Working with sales and not against them
- A look at CDD rules—beneficial owners, controlling
person and the form
- Renewals, IOLTAs, Trusts and Multi-tiered business
ownership
Who Should Attend?
This webinar will benefit BSA Officers, BSA Support
personnel, Deposit Operations, Compliance Officer and
Training.
Instructor
Deborah Crawford is the President of
Gettechnical Inc., a Virginia based training company. She specializes
in the deposit side of the financial institution and is an instructor
on IRAs, BSA, Deposit Regulations and opening account procedures.
She was formerly with Hibernia National Bank (now Capital
One) and has bachelor's and master's degrees from Louisiana State
University. She has 30+ years of combined teaching and banking
experience.
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