KYC CAUTION

Whether we get the Know Your Customer as proposed, as it may be amended, or not at all for awhile, you may be sure - sooner or later - we'll get one.

In the meantime, don't be lulled by all the hoopla going on into thinking you don't need that KYC policy. The examiner will still be looking for it, even if you don't have a "checklist" of what should be in it. The KYC Reg was left vague so your KYC policy would be engineered to fit your location, your type of business, and your risk. Write it carefully - but DO write it!

Copyright © 1999 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 9, No. 2, 2/99