BSA/AML Student Exercises Dec. 2022

involved, efforts will be made to assure that the customer's privacy rights are respected. Additionally, those records related to the identity of a bank customer must be maintained for 5 years after the account is closed. A list of records has been provided below for those record keeping requirements that were not included in previous topics: Recordkeeping Requirements for Extensions of Credit in Excess of $10,000 (not secured by real property) Specific loan purpose-lenders must inquire about the specific purpose of each loan where the amount is more than $10,000 unless it is secured with real estate. Descriptions such as "personal" or "personal expenses" are not acceptable. Even loans secured with savings accounts or certificates of deposit must have a specific purpose. If the customer is reluctant to provide a reason because it is a personal family matter, then a purpose such as "help son with legal matter" is sufficient. Regulators will spot-check the Bank's loan files to determine whether the purpose is recorded. Some bankers think this rule does not apply to loans secured with savings accounts or certificates of deposits because the customer is really just borrowing his/her own money. Often, these loan files will have as a purpose only the term "share loan" or "savings account loan." The lenders must ask customers to specify the intended use of the loan proceeds, for example, taking a vacation, buying furniture or paying college expenses. Although this type of inquiry may seem intrusive to your customers, lenders must explain that federal regulations require you to record a specific purpose for the loan. Record keeping should be kept for extensions of credit in an amount over $10,000, except when the extension is secured by an interest in real property. The following should be maintained: A record of any advice, request or instruction received or given to another financial institution or other person located within or outside the US, regarding a transaction which results in the transfer of funds, currency, checks, investment securities or other monetary instruments or credit of more than $10,000.00 to a person, account or place outside the US., including: • A record of any advice, request or instruction received regarding a transaction which results in the transfer of funds, currency, checks, investment securities, or other monetary instruments or credit of more than $10,000.00 to a person, account or place outside the US. • A record of any advice, request, or instruction given to another financial institution or other person located within or outside the United States, regarding a transaction which results in the transfer of funds, currency, checks, investment securities or other monetary instruments or credit of more than $10,000.00 to a person, account or place outside the US. • Items relating to any transaction of more than $10,000.00 received on any one occasion directly and not through a domestic financial institution, from a bank, broker or dealer in foreign exchange outside the United States. • A check or draft in an amount in excess of $10,000.00 drawn on or issued by a foreign bank which the domestic bank has paid or presented to a non-bank drawee for payment. Signature Cards Documents granting signature authority over each deposit account. • Name of borrower and address of borrower; • Date of loan and amount of credit extended; • Nature or purpose of loan. International Transactions in Excess of $10,000

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