TOPIC: CIP

CIP and E-Sign

Person at a bank ($360MUSA)

I would like to know if anyone is willing to share their procedures or best practices in regard to e-sign for loan documents and sending loan documents via email when there are customers who will require CIP. Are you accepting photo copies of the ID and secondary form of ID? Is anyone asking that the customers come into the branch and use e-sign? Also, if you are accepting images of documents for CIP and don't see the customer(closing loans via email) what other controls are in place to authenticate the customer before moving forward.? Any guidance would be appreciated.

    Nonbank Financial Institutions - NBFIs

    SVP at a bank ($3.3BUSA)

    Looking to see what others do relative to banking independent loan/finance companies that provide lending services to customers of the independent finance customer. Lately, our bank has been opening several accounts for independent lending companies that provide lending services to help individuals purchase residential real estate for investment purposes or for the real estate to be rehabbed and "flipped." According to FinCEN guidance, these type of companies are considered to be an NBFI and are required to have an AML program in place.

    Our question is, what are other banks doing? Are you asking and requiring these types of customers to provide evidence that they have an AML program in place?

    If anyone has an opinion or comments, please share...

      Recordkeeping CDD Questions

      Employee at a bank ($366MUSA)

      Looking to find out from other Banks where they record the CDD questions asked during account opening (we have them recorded on the signature card), as well as any approaches to handling any observed changes, e.g. the customer answered "no" regarding wire activity but has begun receiving/sending wires.

      Thank you for any feedback!

        Fix your policies & procedures now! Final webinar event of the year!

        Start writing better policies & procedures! Join us for our final live webinar event of the year on Wed, December 19th @ 2 PM EST.

        Policies and procedures that are written well are clear, accurate, and easy-to-follow. Failing to meet these three tenets leads most obviously to compliance risk, but poorly written policies and procedures also have direct impacts on employee productivity and customer/member satisfaction – leading to a higher rate of exceptions, rework, and low NPS ratings.

        We will outline the 6 most common mistakes to avoid when writing banking policies and procedures and tips on how to fix them.

        This webinar will cover:

        • How to set up your institution to better write and manage policies & procedures
        • The top 6 most common mistakes to avoid when writing policies & procedures
        • How to fix common errors in your policies & procedures today
        • Real-life case studies demonstrating why it matters

        Register now!

        Cheers,

        The SilverCloud Team

          BSA Language for Vendor Contracts

          VP at a bank ($2.3BUSA)

          I am looking for some "standard" BSA language for use in a vendor contract with a Non-bank Financial Institution relating to overall BSA and specifically addressing adherence with the U.S. Patriot Act and the FIs reliance on the vendors compliance.

            Reduce Exceptions Now! Live Webinar Dec 5th @ 2PM EST

            Join us Dec 5th @ 2PM EST for a live webinar on reducing exceptions at financial institutions.

            Banks and credit unions today invest enormous amounts of time, energy, and money into managing exceptions. Though not all exceptions carry risk, those that do can result in injury to a financial institution’s reputation and bottom line. So what are leading institutions doing to manage risk while still delivering a winning consumer experience?

            We’ll discuss the main drivers of exceptions and what top institutions are doing to address these root causes. Join us to learn about the state of exceptions in the banking industry today!

            We will cover:

            • Strategies for training and managing employees around exceptions
            • Real-industry stories and approaches to reducing exceptions.
            • How to utilize feedback strategies that support different types of learners
            • Tips for enabling employees to more accurately follow policies & procedures
            • How your policy and procedure information impacts the rate of exceptions

            Click here to register!

            Cheers,

            The SilverCloud Team

              Start writing better policies & procedures today! Live webinar on Nov 20th

              Join us for a live webinar on Tuesday, November 20th @ 2PM EST.

              Failure to write clear, accurate, and easy-to-follow policies & procedures most obviously leads to compliance risk, but poorly written policies and procedures also have direct impacts on employee productivity and customer/member satisfaction – leading to a higher rate of exceptions, rework, and low NPS ratings.

              In this webinar, we’ll outline the 6 most common mistakes to avoid when writing banking policies and procedures and tips on how to fix them.

              This webinar will cover:

              • How to set up your institution to better write and manage policies & procedures
              • The top 6 most common mistakes to avoid when writing policies & procedures
              • How to fix common errors in your policies & procedures today
              • Real-life case studies demonstrating why it matters

              Register here!

              Cheers,

              The SilverCloud Team

                PAC Accounts

                AVP at a bank ($6.5BUSA)

                I think this has been asked before but are Political Action Committee accounts (PAC) subject to the Control prong under beneficial ownership requirements? In this case, the individual (Treasurer) on the account has filed the State Board of Elections form and has a TIN. Thanks.

                  Live Webinar Next Week! Top 4 Strategies To Improve Service Level Metrics in Your Bank or CU Call Center

                  Most bank and credit union CEO’s and call centers today are focused on three main metrics: abandonment rates, service levels, and handling times. And it’s with good reason. All three directly reflect an institution’s efficiency and the quality of the consumer experience. Nevertheless, the banking industry today has struggled to improve these metrics.

                  Join us for a live webinar on November 8th @ 2PM EST.

                  In this webinar you’ll learn:

                  • The common challenges in most banking call centers today
                  • Root causes of suboptimal service level metrics
                  • Fresh approaches to rethinking your call center strategy
                  • Real-life case studies demonstrating how other banks and CU’s have addressed this problem

                  Register here!

                  Cheers,

                  The SilverCloud Team

                    CIP / ID Theft Red Flags Vendor Question

                    Manager at a credit_union ($934MUSA)

                    Good morning. I was hoping someone might be willing to share some information.

                    What vendor do you use to locate ID Theft Red Flags on new accounts while you are gathering CIP information? For instance... if an address is a prison, a mailbox location, etc. Or if someone's SSN is associated with a deceased person? That type of thing. And do you like the information your vendor provides... is it useful? User friendly format?

                    Any information is appreciated.

                    Tiffany

                      CIP verification for non-US individuals opening accounts overseas

                      Person at a bank ($9BUSA)

                      Our bank has a very large international client base and have traditionally opened accounts face-to-face at one of our U.S. branches or overseas rep offices. We are now looking into opening personal accounts for international customers that, for whatever reason, cannot come into one of our offices but may have been referred by existing clients. What can we do to meet the CIP verification requirements if we want to continue to conduct documentary verification? Can we rely on a local attorney or a notary? If so, does the bank have to sign a formal agreement with the attorney/notary to provide required CIP services? If we want to go the route of non-documentary verification, what would be a reasonable (and acceptable by regulators) method of CIP verification given that we cannot run credit checks and other third-party sources are very limited in some of these countries? I will add many of our customers are high net worth individuals in countries that regulators would consider high risk. Thanks in advance.