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