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#20250 - 06/11/02 02:55 AM
ChexSystems and FBI Control List
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Anonymous
Unregistered
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Since ChexSystems does not check the FBI Control list, I am wondering how everyone is handling New Accounts. Are you checking new customers to the Control List the next day?
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#20251 - 06/11/02 01:13 PM
Re: ChexSystems and FBI Control List
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Power Poster
Joined: Mar 2001
Posts: 5,063
Pennsylvania
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Our data processing service provider (Metavante) offers a service that compares new customers to both the OFAC and Control Lists and gives us a daily report with possible matches. They will also run a full file comparison whenever we request it to show if any existing customers have been added to either list.
I think Most of the companies that offer OFAC solutions seem to be offering control list solutions as well.
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#20252 - 06/11/02 03:09 PM
Re: ChexSystems and FBI Control List
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Gold Star
Joined: Apr 2002
Posts: 298
Southern State
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My bank uses the WatchDog software and they offer the Control List check as well as the OFAC list check. The software can be loaded on a number of PC's such as the CSR's and wire transfer desks, loan underwriting, etc. and accounts can be checked when opened along with a periodic "scrub" of the entire customer database.
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#20253 - 06/11/02 03:21 PM
Re: ChexSystems and FBI Control List
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Member
Joined: Feb 2002
Posts: 65
Fitchburg, MA
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Karen Sue - Is there an the Internet address for the Watch Dog software?
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#20254 - 06/11/02 03:46 PM
Re: ChexSystems and FBI Control List
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Gold Star
Joined: May 2001
Posts: 279
Texas
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It is www.attustech.com. We use it too, and like it.
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#20255 - 06/11/02 04:11 PM
Re: ChexSystems and FBI Control List
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Power Poster
Joined: May 2002
Posts: 3,608
Near the Land of Enchantment
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Good to hear! We just bought it and are installing it today. I guess that means that the updates to the control list process works well?
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#20256 - 06/11/02 04:29 PM
Re: ChexSystems and FBI Control List
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10K Club
Joined: Oct 2000
Posts: 27,769
On the Net
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Bear in mind that OFAC and Control List hits are to be handled differently. Procedures should be in place accordingly. And while I applaud the integration, is there an official position that the Control List is best reviewed regularly even though the instructions do not say that?
2. Is the search for names on the Control List a one-time search or an on-going search?
Banks are being asked to conduct a one-time search of the Control List pursuant to the guidelines in the Instructions to the Control List.
4. When a Supplement to the Control List is issued, does a bank have to re-search the original Control List again?
No. Banks need only conduct a one-time search for the names on the Supplement. Banks do not have to conduct another full search of the names on the Control List each time a Supplement is issued.
This is a confusing situation. Rhetorical questions. 1) While I believe that it is better to regularly review the List, it isn't required but is it desired by law enforcement since they say we "need only" check it once? 2) This is supposed to be a "need to know basis". Who incorporates it into the database, the bank or the vendor? 3) This is a somewhat confidential procedure, but we discuss it openly here, albeit without names, is this desired by law enforcement? 4) Why do they send us unencrypted files with confidential information?
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AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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#20258 - 06/11/02 04:53 PM
Re: ChexSystems and FBI Control List
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Power Poster
Joined: May 2002
Posts: 3,608
Near the Land of Enchantment
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I asked about the control list confidentiality issue when I was negotiating the purchase of Watchdog. They were in contact with the FBI, and have agreed on procedures whereby both parties sign confidentiality agreements, and the bank actually provides the list to them (theoretically) before they put it into the database.
I haven't been through the process yet, but the premise sounds logical to me, and it did to my regulator.
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#20259 - 06/11/02 05:13 PM
Re: ChexSystems and FBI Control List
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Diamond Poster
Joined: Nov 2000
Posts: 1,820
Southern California
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Andy,
I have a call into Carol Mesheske at FDIC right now. I intend to ask her if we are required to check new customers to the list. I need to know because our auditing firm has stated that the FDIC compliance examiners expect us to do this. This came up during our recent Bank Secrecy Act audit. Hopefully, I will get a return call today. I'll share my findings.
Since we use ChexSystems for OFAC comparisons at new accounts, I am concerned. If we are required to compare new customers to the Control List, I need to devise procedures to make this happen. We have an Intranet and I suppose I could post it there, but I don't know if that is such a good idea considering this information is so CONFIDENTIAL.
As a side note, we use ITI and they will be offering an OFAC module soon. In a conference call last week, they told users that the FBI Control list is not incorporated into this module. They are unable to obtain a copy of the list from the regulatory agencies. In the Control List Q & A it says that we can provide the list to vendors, but I think we would have to make sure they kept it confidential. I'm not sure I would want that responsibility.
Lastly, it is my understanding that if the lists are combined into one, the user must be able to distinguish an OFAC hit from a Control List hit as the rules for handling each are different.
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Dolly Nugent CRCM Opinions expressed are my own.
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#20260 - 06/11/02 05:32 PM
Re: ChexSystems and FBI Control List
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10K Club
Joined: Oct 2000
Posts: 27,769
On the Net
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The Q&A specifically says it is meant to be a one-time search so I do not see the need to check all new accounts, daily. This would be far reaching as it would include your other services as well, not just loans and deposits.
The better question may be, do they mind ongoing search comparisons. My guess is no so long as they intend to advise us when names are removed.
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AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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#20261 - 06/11/02 05:37 PM
Re: ChexSystems and FBI Control List
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Power Poster
Joined: Nov 2001
Posts: 7,988
FINALLY ABOVE the gnat line
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Do you suppose that will change when 10-1-02 gets here and the new USA PATRIOT Act KYC (pardon me, EDD) rules go into effect? I believe that states that we must check all new account applications against any known government list.
Last edited by Louvera; 06/11/02 05:38 PM.
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#20262 - 06/11/02 06:13 PM
Re: ChexSystems and FBI Control List
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Diamond Poster
Joined: Nov 2000
Posts: 1,820
Southern California
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Well here's the scoop. Carol Mesheske of FDIC told me this morning that we are NOT required to verify new customers to the Control List AT THIS TIME. If the proposal goes through that Louvera referred to, we will have to check the Control List as it will be considered a "government issued list."
Carol also said she will send a message to her regional office to make sure that examiners understand the current requirements.
Last edited by Dolly Nugent; 06/11/02 10:51 PM.
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Dolly Nugent CRCM Opinions expressed are my own.
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#20264 - 06/12/02 06:42 PM
Re: ChexSystems and FBI Control List
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Power Poster
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
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Diana--Our systems guy somehow runs the FBI list against our CIF files to identify possible matches. I think he uses the EXCEL list. If you need specific information, let me know and maybe I can hook you up with him. I am definitely not a systems expert.
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#20266 - 06/12/02 08:02 PM
Re: ChexSystems and FBI Control List
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Diamond Poster
Joined: Aug 2001
Posts: 1,033
Marysville, Ca.
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We use ITI software and are outsourced through Fiserv. How can I share this control list with Fiserv without violating the confidentiality of the list as indicated by the agencies? I have had to complete a review manually.
Can someone assist me?
Thanks
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Tina A Sweet-Williams AVP Special Assets mailto:tsweet@goldcountrynb.com
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#20267 - 06/12/02 10:02 PM
Re: ChexSystems and FBI Control List
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Diamond Poster
Joined: Nov 2000
Posts: 1,820
Southern California
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Tina,
I wouldn't want to be the bank that shared the FBI Control list with a vendor - even if the agencies do say we can. How will you ensure that they keep it confidential?
I also agree with the other poster --- the FBI is mostly interested in PAST transactions.
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Dolly Nugent CRCM Opinions expressed are my own.
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#20268 - 06/12/02 10:44 PM
Re: ChexSystems and FBI Control List
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Gold Star
Joined: Oct 2001
Posts: 313
Terminator Country
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Maybe I had an over zealous examiner, but he was adamant that we check CURRENT transactions, including outgoing/incoming wires against the Control List.
In hearing what the FDIC said, these guys took a different tract - just beware that there are examiners and regional individuals that believe that the Control List should be treated like the OFAC list.
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The opinions are mine and do not necessarily reflect those of my employer.
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#20271 - 06/13/02 01:44 PM
Re: ChexSystems and FBI Control List
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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Heck, up until Congress passed the USA PATRIOT Act, there was no law and no regulation that required a check of OFAC lists, either. But regulators can and obviously have used their ability to create a safety and soundness issue to convince us all that OFAC lists are to be checked!
With the implementation of USA PATRIOT Act and its EDD (fka KYC) requirement for new accounts, regulators will now have the ability to back up their requirements with severe penalties.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#20272 - 06/17/02 02:45 PM
Re: ChexSystems and FBI Control List
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Anonymous
Unregistered
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Andy, can you please tell me where I can find the Q&A on the FBI Control List that you referred to in your post -Thanks
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#20273 - 06/17/02 03:35 PM
Re: ChexSystems and FBI Control List
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10K Club
Joined: Oct 2000
Posts: 27,769
On the Net
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My list comes from the OCC and the Q&A is with the Control List. I get a Word and a PDF copy.
I would suggest requesting it from your regulator (in the event there are any differences) or contact me privately. I am hesitant to post the two page document here for bulk and confidentiality reasons.
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AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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#2124947 - 04/04/17 05:19 PM
Re: ChexSystems and FBI Control List
Anonymous
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Platinum Poster
Joined: Aug 2015
Posts: 756
Land Lacking in Lakes, IL
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Reviving an old thread (just 15 years  ) I'm reviewing policies and procedures today and came across a section on the control list. Is this even something that's still in effect? I'll delete it if it's not but just want to be sure.
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