Since the occurrence of September 11th, the heat has been turned up on banks to know their customers and their banking habits to determine if prospective customers are who they say they are. Most of this information has been collected manually or through third-party products that require manual feeds from a core processing system.
McCoy Myers, in conjunction with the McM Advisory Council, has created an automated way of collecting and reporting the required data for Customer Due Diligence, CTR, and SAR. BSALinks will be totally integrated into Meridian and does not require a third-party vendor.
Customer Due Diligence
BSALinks will allow your bank to record Risk Type, Risk Rate, Last and Next Review Date, and MSB Registration Expiation Date, as well as MSB Agent List Received Date. Authorized employees will be allowed to create, save, and print reports based on the criteria you select.
Currency Transaction Reports
BSALinks will print a report of all items $10,000.01 and more reflecting the Risk Type, Risk Weight, and Exempt Status on the report.
If a CTR is required, BSALinks will produce a FinCEN Form 104 report that can be reviewed, certified, and forwarded directly to FinCEN electronically.
BSALinks will allow banks to record the date the bank exempted the account as well as the exemption expiration date and exemption last reviewed date. The bank can mark the exemption Phase I or Phase II.
BSALinks will keep track of the number of CTRs filed on an account so that a bank can determine if the account qualifies for exempt consideration and track of the number of “reportable transactions” on exempt accounts to document that an account continues to qualify for exemption.
Suspicious Activity Reporting
“It is no longer sufficient to have the data; we must do something with it.”
Transaction Monitoring: In BSALinks, banks can define a Dollar Amount, a Number of Times and a Number of Days to Combine. A daily SAR Review Report will print a listing all accounts that the combined amount of Ins or Outs for all related accounts equal to or greater than Dollar Amount. A Multiple Day SAR Review Report will list all accounts on which the combined amount of Ins or Outs on all related accounts was equal to or greater than the Dollar Amount if it appeared more than the Number of Times during the Number of Days.
Account Monitoring: Banks can earmark accounts for monitoring, then enter the number of deposits and the total dollar amount of deposits that the account would normally have in a cycle period. A Deposit Frequency Report will list accounts in which the number of deposits for the cycle exceeds the Deposit Frequency. A Deposit Amount Report will list all the accounts for which the total deposits exceed the Dollar Threshold.
Cash Monitoring: BSALinks will provide a report to alert the bank when an account’s cash transactions are not normal for that account. A report will list all accounts when the total Ins or Outs exceed the account’s 12-month moving average by a factor set by the bank. A screen would allow the bank to analyze the account’s use of cash.
Items Deposited Monitoring: BSALinks will provide a report listing all accounts in which the number of items deposited exceeds the account’s 12-month moving average of number of items deposited by a factor set by the bank. A screen will allow the bank to analyze the history of the number of items deposited.
Large Items Deposited Monitoring. If the account is identified as a CIC and it deposits even one $1,000.00 check, it becomes a MSB by default. BSALinks will monitor and list all checks over $999.99 deposited to accounts identified as CIC.
Wire Transfers Monitoring: BSALinks will provide a report listing all accounts in which the number or total dollar amount of incoming and outgoing wires exceeds the account’s 12-month moving average of the number or total dollar amount of wires by a factor set by the bank. A screen will allow the bank to analyze the history of the number or total dollar amount of wires.
ACH Activity Monitoring: BSALinks will provide a report listing all accounts in which the number or total dollar amount of ACH activity exceeds the account’s 12-month moving average of the ACH activity by a factor set by the bank. A screen would allow the bank to analyze the history of the ACH activity. An exception report will list all International ACH activity and reclamations.
SAR Filings: BSALinks will allow banks to record the date a SAR is filed, SAR Control Number, and SAR Next Review Date. Authorized employees will be allowed to create, save and print reports based on the criteria you select.
