Monitoring of Missing Business Profiles

Employee at a credit_union ($1.9BUSA)
We currently use Verafin to enter information for Business Profiles (questionnaires) for our Business Members. We were wondering how everyone monitors for missing questionnaires for Business Accounts. We currently have an excel spreadsheet where we put any missing questionnaires for new Business accounts, loans, shares that are opened but we are looking for a better alternative so it's not manual.

Thank you in advance!

Political Fund Account

SVP at a credit_union ($463MUSA)
This is new to us, does anyone have a procedure or experience with accounts for the purpose of political fund raising? Should they be treated like a business/corporation, how do we define the legal entities for this account?

It seems like these would be a high risk account from a BSA standpoint, are you aware of any special practices?

As a credit union, are we prevented from opening these kinds of accounts?

Thank you for sharing your knowledge.

Business Online Banking Policy

AVP at a bank ($64MUSA)
Good afternoon. My FI recently got set up to provide Business Online Banking, now the question that has come up is, do we include the Business Online Banking to our wire/ACH Policy, or would it require a policy of itself? 
Anyone willing to share their business online banking policy, would be greatly appreciated. :) 

Scholarship Advertisement

VP at a bank ($569MUSA)
The bank has started a Internship Scholarship. Paid internship; renewable scholarships with 2 awarded each year. In the ad, they want to say one scholarship will be given to a minority student. I don't know if having that in the ad is warranted? However, if we didn't add that language, that may affect applications and in the interest of full disclosure, this may be necessary. Thoughts?

HMDA Process & Owners

VP at a bank ($595MUSA)
Hi there, I was looking for some feedback on your HMDA process. We are struggling with our HMDA process. Currently our Loan Ops completes our HMDA form, Compliance then completes a the same exact form (because they "do not trust" the Loan Ops folks), and then a second person in Compliance reviews the form that was completed was correct. I was curious as to:

  1. Who owns the HMDA data gather process?
  2. Who reviews the HMDA data?
  3. Which person approves the data to go on the LAR?
  4. Are the HMDA data gathering forms scanned? If so, is it just the form or are the documents used as evidence scanned.. or both?
If it's easier to e-mail about this my e-mail is: gwatson@vapartnersbank.com

SAR Filing

Employee at a bank ($631MUSA)
Hello! 
We are going to file a SAR on a business for structuring and wondering if we need to also include the signers of the business on the SAR, or just the employee who did the transactions?

Designation of Exemption

Person at a bank ($254MUSA)
We have an incorporated company that has been exempted from CTR filing for many years. They were a publicly traded corporation that was a Phase I exemption. The company has changed their name and has become an LLC and is privately held.  We would like to change their exemption status to Phase II.  Can this change be immediate or do we have to wait for 5 reportable transactions under the new name?