BSA/OFAC Data Request List

Information for
Financial Institution IT Managers

We have heard from many of our members, who work in institutions under $500 million, that it is not easy to get the data required to perform the kind of risk assessment regulators are asking for.

It seems to us the best people to ask about what kind of data is available to small financial institutions, would be the institution’s IT manager, or in some cases it may be the Core Processor Relationship Manager.

This page generally outlines the data needed to get a risk assessment done that satisfies regulatory expectation.

It would be a huge favor if you would check out the data request list at right and then, (a) call George Self, the Coalition Board Member who is guiding this project) (828-230-5802) or email him and advise us, in your opinion, if the data is available in either a OCR-readable or CSV format?  If only some of the data is available, how much?  If the data exists in different files or tables, can it be exported to a file with a common field, such as Account Number?

We would also like your opinion regarding whether or not this data is likely to be available in an institution under $500 million. And, last of all, you could help us  speak the language to other IT professionals as to the best way to ask for the information, in technical terms.

Thank you very much for your help.  Please contact us if you have questions or comments.

Data Request List

Initially, the data will consist of twelve consecutive months; data can be in twelve separate CSV or XL format files.  After the first run, the data should be output monthly, by the 10th of the month following the previous month-end.

Base Data Request

Data Run date

Customer Name/Physical Address (plan on verifying the addresses with USPS if necessary)

Customer ID Number

Date Account Opened

Branch Assignment

Deposit Account Number, Type, Balance

Loan Account Number, Type, Balance

Service Account Type (Deposit Box, ACH, RDC, etc.)

Date, Number and Dollar Volume of each transaction in each deposit account

Date, Number and Dollar Volume of each transaction in each loan account

Date, Number and Dollar Volume of each transaction in each service account (ATM, ACH, etc.)

List of Service Accounts showing which account number paired with

For example, if an account is approved to send Wires, then a data set which includes the following:

Customer Account Number

Customer ID Number

Date of Wire In or Out

Transaction Number or ID

Payable to Whom (Beneficiary)

Originator of Wire

Beneficiary Address (including City, State and Zip; if out of USA include the foreign address)

Originator Address ((including City, State and Zip; if out of USA include the foreign address)

Date of Origination

Date of Receipt (if known)

Originator’s Bank

Beneficiary’s Bank

Amount

If an account is approved for Redeposit Capture, or On Line Banking, include the following:

Customer Account Number

Customer ID Number

Transaction Number or ID

Payable to Whom (Beneficiary)

Beneficiary Address (including City, State and Zip; if out of USA include the foreign address)

Date of Origination

Beneficiary’s Bank

Amount

Appended Third-Party Data to each account

HIDTA/HIFCA

Geo-coding: Census Tract, Lat-Long

NAICS code for all business accounts

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If the data exists in separate files or tables, please export in such a way as there is a key field (common field) in each file or table.

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Link to the Federal Financial Inter-Agency Examination Counsel (FFIEC) BSA Examination

BSA/OFAC Risk Assessment Page

This Federal Financial Institutions Examination Council (FFIECBank Secrecy Act (BSA) /Anti-Money Laundering (AML) Examination Manual provides guidance to examiners for carrying out BSA/AML and Office of Foreign Assets Control (OFAC) examinations. An effective BSA/AML compliance program requires sound risk management; therefore, the manual also provides guidance on identifying and controlling risks associated with money laundering and terrorist financing. The manual contains an overview of BSA/AML compliance program requirements, BSA/AML risks and risk management expectations, industry sound practices, and examination procedures. The development of this manual was a collaborative effort of the federal and state banking agencies 1 and the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury, to ensure consistency in the application of the BSA/AML requirements. In addition, OFAC assisted in the development of the sections of the manual that relate to OFAC reviews. Refer to Appendices A (“BSA Laws and Regulations”)B (“BSA/AML Directives”), and C (“BSA/AML References”) for guidance.Federal Financial Inter-Agency Examination Counsel