CDD: One Year Later | Survey Request

It's officially been one year since the CDD rule went into affect. Have you had an exam since then? What aspects of CDD and beneficial ownership, if any, did the examiner focus on? 

We're doing a short survey on the impact CDD is having on recent exams and would appreciate if you could take a few minutes to fill it out. We're happy to share the results if you participate. 

Thank you! 


    Basic Knowledge/Risks of Private Banking for BSA

    VP at a bank ($7.6BUSA)
    I am interested in learning more about private banking. I have read the exam manual and I know what I know from my CAMS course, but still would like some real world pitfalls. I have heard from others to avoid calling your program "the private bank" because often you are not really doing a true private banking relationship but the name itself draws scrutiny. 

    We are not talking about banking foreign individuals, but more or less just personalized service. I intended on having an increased level of CDD/KYC but other than that, can anyone share any stories or regulator criticisms you have had?

    Thank you, 

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