Review Alliance: Did You Know?

  • Did you know that it’s important to monitor all non-resident alien accounts?

    - The Bank should ensure all non-resident alien customers are in non-interest bearing accounts.

    - The Bank should review and obtain current W8-BENs on all non-resident aliens annually.

  • Did you know that it’s important to keep a log of Adverse Actions taken based on CIP?

    - The Bank should provide an Adverse Action notice to the customer at the time the account is denied.

    - The adverse action notice should contain a number the customer can call for more information.

    - The Bank should maintain a log of denied accounts to help avoid any potential UDAAP concerns.

  • Did you know that it’s a best practice to have a risk assessment that contains quantitative and qualitative data?

    ·       The Bank’s BSA officer, or designee, should review the data at least annually to ensure accuracy.

    ·       A model validation should be completed to ensure data is being captured accurately and accurately reflects the risk present by the customer base and transaction activity.