Skip to content
BOL Conferences
Page 3 of 4 1 2 3 4
Thread Options Tools
#75306 - 04/30/03 01:56 PM Re: CIP
BankerMama Offline
Diamond Poster
BankerMama
Joined: Jun 2001
Posts: 1,543
I just "skimmed" over it. Looks good.

Return to Top
General Discussion
#75307 - 04/30/03 02:20 PM Re: CIP
Summer101 Offline
Platinum Poster
Joined: Jun 2001
Posts: 644

Return to Top
#75308 - 04/30/03 02:38 PM Re: CIP - Just issued 10:41AM
Anonymous
Unregistered


Return to Top
#75309 - 04/30/03 02:41 PM Re: CIP - Just issued 10:41AM
Al Miller Offline
Diamond Poster
Al Miller
Joined: Oct 2000
Posts: 2,416
Pleasanton CA USA
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.

Return to Top
#75310 - 04/30/03 02:43 PM Re: CIP - Just issued 10:41AM
Retired DQ Offline
10K Club
Retired DQ
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
NOW you tell me, it's already printing...
_________________________
Get your facts first, then you can distort them as you please. - Mark Twain

Return to Top
#75311 - 04/30/03 02:55 PM Re: CIP - Just issued 10:41AM
Strout Offline
100 Club
Joined: Nov 2001
Posts: 164
A beach in the USA
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!

Return to Top
#75312 - 04/30/03 02:57 PM Re: CIP
Anonymous
Unregistered

You can also access them here:
http://www.bankersonline.com/aml/326finalrule.pdf

We'll have analysis/summary up PDQ on our AML/USA PATRIOT Act page.

It's up now. Link to it here:
CIP Final Rule: 10 Quick Changes

Return to Top
#75313 - 04/30/03 02:57 PM Re: CIP - Just issued 10:41AM
SMQ, CRCM Offline
Power Poster
SMQ, CRCM
Joined: Apr 2001
Posts: 4,828
Between the lines
Quote:

Reminder. Put pre-punched paper in the printer. Much easier than having to punch all 106 pages later.


Thanks for the tip, it's all in the details!!
_________________________
NOLA is my Beach!

Return to Top
#75314 - 04/30/03 03:05 PM Re: CIP
PABanker Offline
Gold Star
PABanker
Joined: Dec 2000
Posts: 491
Blue Ball, PA 17506
CIP rules are issued!!!!

Return to Top
#75315 - 04/30/03 03:07 PM Re: CIP
Anonymous
Unregistered

YEAH!!!! I'm actually thrilled that they are finally out!!! I'll be diving into the 106 pages pronto!

Kara S

Return to Top
#75316 - 04/30/03 03:11 PM Re: CIP
MackenzieS Offline
Diamond Poster
MackenzieS
Joined: Jul 2002
Posts: 1,722
Oklahoma
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!

Return to Top
#75317 - 04/30/03 03:20 PM Re: CIP
BeachGirl Offline
100 Club
Joined: Sep 2001
Posts: 206
Myrtle Beach, SC
Quote:
--------------------------------------------------------------------------------


We'll have analysis/summary up PDQ on our AML/USA PATRIOT Act page.

Thank you, Mary Beth!
_________________________
Thanks for all of your help!

Return to Top
#75318 - 04/30/03 03:43 PM Re: CIP
Anonymous
Unregistered

It's here - just got an e-mail - it's 106 pages - see it at complianceheadquarters.com.

Return to Top
#75319 - 04/30/03 03:53 PM Re: CIP
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,763
On the Net
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

Return to Top
#75320 - 04/30/03 04:40 PM Re: CIP
Sam Ott Offline
Power Poster
Sam Ott
Joined: May 2001
Posts: 3,573
Norman, Ok, USA
A summary, "CIP Final Rules: 10 Quick Changes" is available on the BOL AML/USA PATRIOT Act page.

CIP Final Rules: 10 Quick Changes
Last edited by mbguard; 04/30/03 05:04 PM.
_________________________
Sam Ott
Associate Editor
BankersOnline.com

Return to Top
#75321 - 04/30/03 05:01 PM Re: CIP
Anonymous
Unregistered

Hello,

I received the final ruling this morning. Make sure your printer has a lot of paper as the report is approximately 106 pages! Have fun

The website is: www.treas.gov/press/releases/reports/326finalrulebanks.pdf

Return to Top
#75322 - 04/30/03 05:34 PM Re: CIP
Retired DQ Offline
10K Club
Retired DQ
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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

Return to Top
#75323 - 04/30/03 07:56 PM Re: CIP
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,763
On the Net
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

Return to Top
#75324 - 04/30/03 09:47 PM Re: CIP
Anonymous
Unregistered

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?

Return to Top
#75325 - 05/01/03 12:45 AM Re: CIP
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,763
On the Net
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

Return to Top
#75326 - 05/01/03 01:15 PM Re: CIP
Anonymous
Unregistered

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?

Return to Top
#75327 - 05/01/03 01:16 PM Re: CIP
BankerMama Offline
Diamond Poster
BankerMama
Joined: Jun 2001
Posts: 1,543
Hey, who won our contest?

Return to Top
#75328 - 05/01/03 01:24 PM Re: CIP
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,763
On the Net
Quote:

Hey, who won our contest?




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!
_________________________
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

Return to Top
#75329 - 05/01/03 01:27 PM Re: CIP
Anonymous
Unregistered

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!

Return to Top
#75330 - 05/01/03 01:31 PM Re: CIP
Skittles Online
10K Club
Skittles
Joined: Sep 2002
Posts: 13,965
TN
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.
_________________________
My Opinions Only

Return to Top
Page 3 of 4 1 2 3 4