Updating BSA Policies To Accommodate Section 326 Rule

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Question:

As part of our BSA Policy, I wrote a new customer information procedure guideline. My understanding is that we also need a separate Policy, but someone in our deposit compliance area disagrees. What exactly do we need policywise for BSA?

Answer:

Answer by Lucy Griffin:

Policies for specific laws may be combined. You may, for example, have a policy that encompasses BSA, OFAC, and USA PATRIOT Act requirements that append to both laws. The procedures are another matter because the steps to comply with customer identification may differ from OFAC list checks.

Policies should be a statement of the institution's goals, including compliance. As such, a policy can include several related laws. Procedures should contain more detail and be jobspecific.

Answer:

Answer by Ken Golliher:

The proposed CIP regulations clearly indicated that your CIP program is to be included in your antimoney laundering policy. For a bank, your antimoney laundering policies would normally be incorporated in your BSA policy.

Like Lucy, I would suggest that you need one policy that addresses CIP, AML and BSA. You are talking about common personnel, goals and objectives and nothing will be gained by establishing separate, overlapping documents.

First published on BankersOnline.com 05/12/03