Good afternoon Everyone,

Do most banks as estimated average of transactions and dollar amounts for individuals? I know for businesses it is a good idea to ask those types of questions, but was not sure if it would be a good idea to ask for individuals. For example: would you ask an individual that is opening up a individual checking account about wire activity (getting the estimated monthly average of transactions and dollar amounts)? Thank you for your thoughts

We do at the recomendation of auditors - it is a waste of time. Nobody knows what their activity levels are/will be. The branch likes having the form to refer to when we ask them to contact the customer for suspicious activity because they can say "you said you were going to do x activity at account opening and now you're doing y, why is that". The branches do not like to fill the form out and somehow can't figure out to do it correctly either.

So the branches don't like to fill out the form and sometimes get it wrong, but they like having form if they need to contact the customer about questionable activity. And you suggest it's a waste of time.

Auditors sometimes make good suggestions. Sometimes their suggestions are ill-conceived. This is one of the latter, and the more that bank management fails to push back on ill-conceived auditor suggestions like this one, the more likely the ill-conceived ideas are to become "best" practices. It would not be unreasonable, I think, to go back to the auditors now and tell them that you tried it out, and there has been negligible benefit derived from it when compared to the speed bump it creates in the new account process. The short version is, "Thanks, but no thanks."

There simply is no justification in the FFIEC BSA/AML Exam Handbook for trying to quantify a new household account customer's expected activity. Let your AML monitoring system plug in a reasonable set of numbers for new household accounts and use it as a starting point for your system to "do its thing" with account activity. Don't waste new accounts personnel time posing off-putting questions as part of the new account interview for consumer accounts. Save that sort of "interrogation" for business accounts.

John, yes that is my viewpoint. I was not here when it was implemented. I'd be more than happy to do away with the form. The comments on not wanting to fill out the form/liking it when they need to inquire on activity is feedback I have received through conversation. Just passing along information.

I agree that anticipated activity for regular retail consumers isn't helpful, however we do it as it a requirement of our regulators. However, certain CDD questions (Occupation, purpose of account, etc.) can be quite useful when conducting investigations.

I agree 100% with the CDD questions being useful.

Appendix K in the FFIEC BSA-AML examination manual can be cited for the premise that banks need a basic profile for domestic consumer customers. (In my opinion, that includes occupation, employer, purpose of the account, types of deposit and payment mechanisms expected, etc. Getting dollar amounts is ridiculous.) That, combined with "threshold" monitoring should be enough.

If examiners say you need more, your bank has to deal with their personal opinions. If auditors say you need more, well, you hired them and you pay them. You are entitled to demand they have better judgment.

A "risk based" program isn't supposed to assume that everyone is high risk.