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#91034 - 06/30/03 05:18 PM
Re: 314(a) Searches - Do not keep the names!
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Diamond Poster
Joined: Jul 2002
Posts: 1,722
Oklahoma
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Quote:
After you have done your search for the 314(a) requests, DO NOT KEEP A COPY OF THE LIST!
"GASP!" - I am sorry, banker's do not understand this meaning. We keep everything! I too have held onto mine to "show my willingness to comply" to these time consuming requests.  I sure would like to chunk them though, they get awfully bulky and I have had to aquire a "secure setting" in which to store the darned things.
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#91035 - 06/30/03 10:05 PM
Re: 314(a) Searches - Do not keep the names!
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Diamond Poster
Joined: Mar 2002
Posts: 2,355
The O.C., California
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Bonnie, did the speaker explain why we should not keep the list? 
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I can explain it to you. I can't understand it for you.
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#91036 - 06/30/03 11:02 PM
Re: 314(a) Searches - Do not keep the names!
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Power Poster
Joined: Jun 2001
Posts: 8,272
Where the heart is
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He said that the names were extremely confidential and FinCEN did not want the possibility that the lists could be leaked (a la the original "Control" list.) Of course he didn't have an answer to the question about the non-secure method that FinCEN uses to SEND the list..... What's the expression? Do as I say, not as I do? I posted this because he really made a big, big, big deal about this at the seminar.
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CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'
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#91037 - 07/01/03 01:25 AM
Re: 314(a) Searches - Do not keep the names!
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Platinum Poster
Joined: Jul 2001
Posts: 564
South Carolina
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Quote:
Tell you auditor to contact Mr. Davidson in Washington DC. Send me a PM and I'll give you his number.
"That's one ringy-dingy."  (Sorry, couldn't help myself).
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#91039 - 07/01/03 03:34 PM
Re: 314(a) Searches - Do not keep the names!
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10K Club
Joined: Jul 2001
Posts: 85,275
Galveston, TX
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Well, I for one would not put much credence in a statement by one person made at a conference on such a controversial issue. To rely on a verbal statement in such a manner is a very dangerous practice. If it is that important, then written guidance should be promulgated by the proper enforcement agency(ies). Otherwise, take a deep breath and let it go........
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#91040 - 07/01/03 05:08 PM
Re: 314(a) Searches - Do not keep the names!
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Power Poster
Joined: Jun 2001
Posts: 8,272
Where the heart is
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Quote:
At the seminar, he was asked what if FED wasn't the banks regulator? He said it didn't matter, don't keep the list. And he expressed that to the other regulators in the room.
Right Bonnie?
Yes he did, and the other regulators nodded their head. He also gave out his phone number for anyone to call on the subject. I now hear, however, that he was unpleasently surprised by the number of calls he got on this.
IMHO, this serves as an example of how difficult compliance management and communication can be. Apparently, this is FinCEN's wish, and they strongly communicated it to this gentleman, but where's the back up on this? Where's the official communication? Where's the FAQ?
So while the agencies keep hounding banks on how important it is to have clear lines of communication and responsibilities, when it comes to a fast changing area such as USA PATRIOT Act, I think the agencies are finding out how difficult it is to really do. That commercial on herding cats comes to mind....
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'
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#91041 - 07/01/03 06:58 PM
Re: 314(a) Searches - Do not keep the names!
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10K Club
Joined: Oct 2000
Posts: 27,769
On the Net
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I agree. An official word should be put out, officially.
Likely many of you haven't heard of the 314(aa) lists. These are ultra confidential and have to be researched the same day received and responded to. NOT.
My point is, if you didn't hear about trashing the list copy here on BOL, how many of us would know at all? There is no 314(aa) list and that is why you don't know about it.
I won't destroy my 314(a) until directed to do so.
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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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