CIP and Government Request Procedures

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Question:

After a recent exam, our institution had an informal recommendation to address procedures for addressing gov't requests for information (separate from OFAC and 314a) in our CIP Program. Any help on what is this informal recommendation should include?

Answer:

I would contact your regulator and ask them to provide you with additional guidance. They could be referring to how your institution handles subpoenas or procedures on how to handle Law Enforcement requests from a SAR filing. Until you get better direction, it is unclear what is being required.

First published on BankersOnline.com 2/7/05