A few years back an examiner included in her findings that we needed to search our ACH files for common ATM service providers to help us find any customers we have not identified as owning ATMs. She provided us with a list of service providers and said we should search one month each year. At some point the frequency of the searches was increased and they are now being done every day of the year. I don't know why this changed as the employee responsible no longer works here. We have to do all the searches manually as we are a very small bank and have to software to help. I am now wanting to change back to the original timeline but am wondering what others are doing. Any input would be appreciated.

Well, that's interesting, Complycated.( like your user name). Would you be willing to share the list of service providers. At the moment I am visiting customers only when I suspect they may have an ATM on premises. And I only do this once every six months if I suspect. We are a small Community Bank too and we do not have an automated system to do a search like that or a large staff to delegate that task.

The list we were given is: FDRetail ATM; RBS; Worldpay; Coredata; FirstData; Datastream; Elan FS; Cash Depot; Cardtronics; CDS; EFUNDS; SWITCH; Metabank; Innobeta; MVNT; FDC Star System; Global

I would be interested to know if anyone has an updated list or if these are still applicable.

A few years back an examiner included in her findings that we needed to search our ACH files for common ATM service providers to help us find any customers we have not identified as owning ATMs.

Wow. Just shows how some examiner's personal preference or opinion can morph out of control at a bank. Assess your risks and adjust your controls appropriately.

In my opinion, Lily C's technique is more than adequate for a community bank; you are not looking for illegal activity. To me, a quarterly or even semi-annual search based on identifiers would conducted as an excess of caution.

I'm not certain where an "exam finding" falls in the context of MRAs or MRIAs, but I would want to see the written report of exam rather than rely on oral history and decisions made by a former employee. To be clear, I think the examiner was offering a personal opinion that was unsupportable and it has morphed into a practice that is ridiculous.

Thank you all for your responses.

On my last outside BSA audit this same thing was brought up. I agreed to search quarterly. We are a very small community bank as well. How I do it is I export and convert our ACH file to excel then I do a find & select search for the ATM networks at the most it takes me 20 minutes.

We also got the same comments a while back in regards to running a search. I do mine on a quarterly basis, and in addition to the list provided by the examiner I also update mine according to the settlement agents used by ATM owners that disclosed to us at account opening. I've found that more previously unknown ATM owners have been identified with service providers added to the list than the original list itself.

I've also found that when using a BIC program to run the search (if you have access to BIC), it's extremely sensitive to capitalization, use of wildcards, etc. so the best way I've found to validate it was to ensure that all my known owners appeared on the report...took a while to get it up & running but it works beautifully now.

Just to tag onto this, we run our ACH scrub yearly covering a robust month of ACH credit/debit transactions, and include in the search such trigger words as "Western Union", "Pronto", etc. Our annual search enables us to identify potentially undisclosed MSB's as well as businesses with ATM's, and validates those customers previously identified.

Senior management recently attended some form of conference held with the FDIC, not sure if this is a regional thing; however they mentioned that in addition to the above, we were to do an ACH scrub for the known Medical Marijuana companies located in the region using the information provided through the state registries. While this was just "encouragement", I'm guessing that it got through to the senior management team enough that they'd bring it to my attention for a reason.

.....because we have nothing better to do, apparently!

Tell them you will get right on it but it will require some field research to properly identify these specific entities and whether they actually sell the stuff

That's the kind of rote suggestion regulators make without regard to a cost/benefit analysis. (It's also the type that management can easily comprehend and think they've heard something important.) However, I think it's good to contrast this with the search for ATM activity that is the genesis of this thread. At least there is an argument that the marijuana related business is operating in violation of federal law. That simply doesn't apply to private ATMs.

In comparison, there is no comparison.

Thank you for sharing your list. I just started a manual monthly search of ATM providers after talking with other BSA Officers a few months ago. It wasn't brought up during my exam in April, but the auditor asked for my list during her review last month. I found two ATM customers with my most recent search with the keyword SWITCH and ATM. I also search FDRetail and Paymentech keywords.

Would you by chance have New York FDIC as your regulator? We had a similar experience during our exam last year. The BSA examiner left us with a two-page list of recommendations for enhanced AML/BSA compliance. We nodded our heads during the exit, politely took the list from the examiner, and prayed that only half of the list would actually make it to the report because we, too, are a small bank with no automated AML software tools and limited Operations staff. Much to our delight and surprise, there were zero BSA findings or violations on the final exam report, and only one of her two-page list of recommendations and "suggestions" made it to the report (monitoring customers with private ATM's on-site, which seems to be the BSA recommendation du jour). The examiner did mention that she had just spent a week at a BSA conference just prior to our exam, and learned all these ideas at the conference.

Just love the one size fits all exams

But don't you need to do some checking to know what size (risk) you are?