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#75307 - 04/30/03 02:20 PM
Re: CIP
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Platinum Poster
Joined: Jun 2001
Posts: 644
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#75308 - 04/30/03 02:38 PM
Re: CIP - Just issued 10:41AM
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Anonymous
Unregistered
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#75309 - 04/30/03 02:41 PM
Re: CIP - Just issued 10:41AM
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Diamond Poster
Joined: Oct 2000
Posts: 2,416
Pleasanton CA USA
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Reminder. Put pre-punched paper in the printer. Much easier than having to punch all 106 pages later.
_________________________
Al Miller, CRCM
Opinions expressed are my own and not necessarily shared by my employer.
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#75311 - 04/30/03 02:55 PM
Re: CIP - Just issued 10:41AM
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100 Club
Joined: Nov 2001
Posts: 164
A beach in the USA
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You know, I don't hesitate to read a 500 page mystery at the beach but just thinking about reading these 106 pages is positively making me queasy!!!!
I think the new Harry Potter book will be a much better read!!
_________________________
That's my story and I'm sticking to it!
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#75315 - 04/30/03 03:07 PM
Re: CIP
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Anonymous
Unregistered
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YEAH!!!! I'm actually thrilled that they are finally out!!! I'll be diving into the 106 pages pronto!
Kara S
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#75316 - 04/30/03 03:11 PM
Re: CIP
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Diamond Poster
Joined: Jul 2002
Posts: 1,722
Oklahoma
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Quote:
We'll have analysis/summary up PDQ on our AML/USA PATRIOT Act page.
Mary Beth, this is why we love you!  Now....lets get to reading!
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#75317 - 04/30/03 03:20 PM
Re: CIP
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100 Club
Joined: Sep 2001
Posts: 206
Myrtle Beach, SC
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Quote:
--------------------------------------------------------------------------------
We'll have analysis/summary up PDQ on our AML/USA PATRIOT Act page.
Thank you, Mary Beth!
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Thanks for all of your help!
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#75318 - 04/30/03 03:43 PM
Re: CIP
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Anonymous
Unregistered
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It's here - just got an e-mail - it's 106 pages - see it at complianceheadquarters.com.
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#75319 - 04/30/03 03:53 PM
Re: CIP
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10K Club
Joined: Oct 2000
Posts: 27,763
On the Net
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Anon, I'm just funning with you, but if your last name was Revere we'd all have English accents. See SG's post above from 9:20 AM.
_________________________
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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#75320 - 04/30/03 04:40 PM
Re: CIP
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Power Poster
Joined: May 2001
Posts: 3,573
Norman, Ok, USA
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A summary, "CIP Final Rules: 10 Quick Changes" is available on the BOL AML/USA PATRIOT Act page.
CIP Final Rules: 10 Quick Changes
_________________________
Sam Ott
Associate Editor
BankersOnline.com
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#75322 - 04/30/03 05:34 PM
Re: CIP
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10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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Nice piece of work: "10 Quick Changes". From the people I know, it is almost as if banks are already complying... just need to update the BSA policy! 
_________________________
Get your facts first, then you can distort them as you please. - Mark Twain
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#75323 - 04/30/03 07:56 PM
Re: CIP
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10K Club
Joined: Oct 2000
Posts: 27,763
On the Net
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The ABA session was good today. I like that the signatories ID requirements differ from the proposal. That was something we didn't discuss much.
Certainly this will be a good exercise in compliance integration as this will touch so many areas within the bank.
I am also glad we are not into dealer paper any longer.
_________________________
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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#75324 - 04/30/03 09:47 PM
Re: CIP
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Anonymous
Unregistered
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Quote:
The ABA session was good today. I like that the signatories ID requirements differ from the proposal. That was something we didn't discuss much.
Certainly this will be a good exercise in compliance integration as this will touch so many areas within the bank.
I am also glad we are not into dealer paper any longer.
Andy, why do you add the part about the dealer paper?
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#75325 - 05/01/03 12:45 AM
Re: CIP
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10K Club
Joined: Oct 2000
Posts: 27,763
On the Net
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Because I don't want to depend on some of the dealers I remember to be responsible for executing my CIP program on car paper. There are some safe harbors but these are lost when a non-regulated entity does this for you.
_________________________
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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#75326 - 05/01/03 01:15 PM
Re: CIP
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Anonymous
Unregistered
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Quote:
Because I don't want to depend on some of the dealers I remember to be responsible for executing my CIP program on car paper. There are some safe harbors but these are lost when a non-regulated entity does this for you.
Andy, we ran into this with our very large indirect program in a couple ways. In a previous CRA exam, they told us that we were responsible for making sure that the rate spread between the contract rate and buy rate (which we cap at 3%) was not discriminatory; that minorities and female applicants were not being booked at higher spreads on a widespread basis than less protected classes. Because of this, we do a self-analysis yearly based on FDIC recommendation, but are always cognicent now that the dealer is in effect now part of our compliance concern. In addition, we had to stop having dealers send us a copy of the drivers license with the loan papers to be booked, because the FDIC said that it could be discriminatory and prejudicial, even though we would not receive the copy until after a loan decision was made. This is why I asked the original question - without being ignorant here, what is it you suggest we do to make sure that dealers are not violating our CIP Program?
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#75329 - 05/01/03 01:27 PM
Re: CIP
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Anonymous
Unregistered
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Quote:
Peg E by the rules, bwest was the closest. But hey. Don't we all really win since the CIP belongs to all of us!
Shirts for both. BTW, Jim Bedsole had to provide us a roadmap of who bwest and Peg E are now. I hadn't followed their user name transitions!
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#75330 - 05/01/03 01:31 PM
Re: CIP
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10K Club
Joined: Sep 2002
Posts: 13,965
TN
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When the new rules came out yesterday I printed them off. We put a bow around them and delivered them to the BSA officer who was in a meeting. He got a huge kick out of that one.
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My Opinions Only
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