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#75281 - 04/25/03 09:36 PM
Re: CIP
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100 Club
Joined: Oct 2002
Posts: 204
Arkansas
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Quote:
I heard from the ABA that the rules will be out Monday (4/28)or Tuesday (4/29). I think they meant 2003!
I received a flyer from the Arkansas Bankers Association for a seminar that states: "Final regulations on Customer Identification Program are finally out. Are you ready?" And at the bottom: "Only 6 months to comply! Sign up today!"
Do they know something we don't or just confident the final rules will be out next week?
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#75282 - 04/26/03 01:17 AM
Re: CIP
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10K Club
Joined: Oct 2000
Posts: 27,763
On the Net
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While I do believe they will be out soon, was that release dated Oct. 2002 or April 2003?
_________________________
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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#75283 - 04/28/03 01:31 PM
Re: CIP
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100 Club
Joined: Oct 2002
Posts: 204
Arkansas
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Quote:
While I do believe they will be out soon, was that release dated Oct. 2002 or April 2003?
Andy, if you are addressing me, the release came out Friday, April 25.
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#75284 - 04/28/03 01:47 PM
Re: CIP
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Joined: Oct 2000
Posts: 27,763
On the Net
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It was a joke. Sorry. I should have added the traditional ![](/ubbthreads/images/graemlins/smile.gif) as we have been expecting this for a long time.
_________________________
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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#75285 - 04/28/03 01:55 PM
Re: CIP
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100 Club
Joined: Oct 2002
Posts: 204
Arkansas
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Quote:
It was a joke. Sorry. I should have added the traditional as we have been expecting this for a long time.
I'm a little slow this morning, only on my second cup of coffee, and it's Monday morning.
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#75286 - 04/28/03 01:57 PM
Re: CIP
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Anonymous
Unregistered
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I am still working on getting good representation from the bank I work for at the ABA seminar on Wednesday. I invited the Insurance Department and they do not think it will apply to them. I know the final rules are not out, but what do you think?
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#75288 - 04/28/03 02:33 PM
Re: CIP
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Power Poster
Joined: Oct 2000
Posts: 5,992
Soaring over Georgia
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Not as of 10:00am EDT on 4/28/03.
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Jim Bedsole, CRCM, CBA, CFSA, CAFP My posts - my opinions
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#75289 - 04/28/03 02:56 PM
Re: CIP
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10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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And not out as of 11:00 am on 4/28/03!
Maybe we should report in hourly!
That was EDT, as well.
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Get your facts first, then you can distort them as you please. - Mark Twain
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#75290 - 04/28/03 04:01 PM
Re: CIP
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Diamond Poster
Joined: Apr 2001
Posts: 2,245
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Quote:
Maybe we should report in hourly!
That could have a MAJOR impact on the "guess the post count" contest!
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#75293 - 04/28/03 05:28 PM
Re: CIP
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10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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This post is turning frivolous... 1:29 EDT-No CIP rules yet... just checking in.
_________________________
Get your facts first, then you can distort them as you please. - Mark Twain
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#75294 - 04/28/03 05:36 PM
Re: CIP
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Anonymous
Unregistered
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Let us be neurotic for you. The BOL team is obsessively/compulsively checking for the CIP rules (just as we have been since SEPTEMBER -- argh!) and we'll let you know the moment anything pops up.
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#75295 - 04/28/03 05:52 PM
Re: CIP
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10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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You guys are the absolute BEST! I think I'll go home now... And MB, you are Tops!
_________________________
Get your facts first, then you can distort them as you please. - Mark Twain
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#75296 - 04/28/03 06:04 PM
Re: CIP
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Power Poster
Joined: May 2001
Posts: 8,458
Somewhere
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Quote:
Let us be neurotic for you. The BOL team is obsessively/compulsively checking for the CIP rules (just as we have been since SEPTEMBER -- argh!) and we'll let you know the moment anything pops up.
I am anxiously awaiting my compliance special briefing from BOL when the rules are out!
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#75298 - 04/29/03 01:24 PM
Re: CIP
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Power Poster
Joined: Nov 2001
Posts: 7,987
FINALLY ABOVE the gnat line
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I just received an e-mail from our rep at Bankers Systems that stated the rules would be issued tomorrow, April 30th.
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"Once you learn to read, you will be forever free." - Frederick Douglass
My Opinion Only.
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#75300 - 04/29/03 06:53 PM
Re: CIP *DELETED*
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Power Poster
Joined: Jun 2001
Posts: 6,153
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Post deleted by zaibatsu
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#75301 - 04/29/03 07:12 PM
Re: CIP
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10K Club
Joined: Oct 2000
Posts: 27,763
On the Net
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I don't know what this has to do with CIP, but you'll be happy to know that I did take a day of vacation last Friday. And I didn't log on until about 8 PM, well after the work day was over. One thing I want to see is the mandatory effective date. AR mentioned October 1 which will give us 5 months instead of the 6 we'd heard about. But without having to acquire the infrastructure to copy IDs it will be easier to implement. I hope there are no hidden requirements to address. I hate those unexpected little additions. I'll have to dust off and update the policy I was working on so many months ago. I wonder how many of us will implement immediately or take our time up until the August - September time frame.
_________________________
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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#75303 - 04/30/03 12:12 PM
Re: CIP
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Gold Star
Joined: Mar 2002
Posts: 451
Everywhere, USA
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On the deadline for compliance with 326, the Oct 1 date was initially targeted in anticipation of a release date that would make for a 6 month lead time to comply. Unfortunately, the affected regulators, a group that is much broader than just the banking regulators, had some discussions that delayed the issuance of the regulation past March. I'm not sure there is an ability at this point to change the Oct 1 implementation as there is some hope of printing the reg in the Federal Register momentarily. If there happens to be some more significant delays, which I think is unlikely at this point, then perhaps the implementation date will get pushed back.
One other thing about the final reg that you might find interesting. Consistent with the proposal, the final reg requires banks to have procedures to identify customers that may be on a government provided list of known or suspected terrorists. There has been much debate on what lists count for Section 326 purposes, e.g., OFAC, FBI, FinCen 314 requests, etc. There are currently NO lists of known or suspected terrorists designated as 326 lists. Any such list distributed by the US that is to be used for 326 purposes will be conspicuously labeled as a 326 list, so there won't be any doubt about which lists you must use for this purpose. AR.
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#75305 - 04/30/03 01:09 PM
Re: CIP
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10K Club
Joined: Oct 2000
Posts: 27,763
On the Net
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The 10-1 date is also what I am hearing. These rules should be released this morning. In hopes that a webmaster hit the upload key to early I have been to the regulatory sites this morning but haven't seen anything yet.
_________________________
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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