Overview
BSA monitors consumer accounts for unusual and suspicious transactions and activity. If BSA has additional questions regarding the source of funds and/or potential suspicious transactions, Relationship Bankers assist in making contact with the client to ask the necessary questions.
Who does BSA ask to assist?
- Lending officer assigned to the loan relationship
- Retail Banker assigned to the deposit account
- Retail banker assigned to the relationship
- Office assigned to the relationship / account
Why does BSA ask for assistance?
- Client contact is required to obtain explanations from the client to justify or explain observed activity.
- Lenders and retail associates are familiar with their clients and are therefore asked to assist in obtaining additional information and assessing the reasonableness of the explanations given.
What is required of associates when contacting clients for additional information?
- Ask specific questions to obtain an explanation for the activity in question.
- Obtain and record responses from the client.
- Determine if the explanation makes sense for the client, who they are, what they do for a living, past experiences or life changing events.
- Make a determination if the answer(s) given are viable.
Retail - BSA Request for Information
When BSA identifies suspicious account activity, a Synapsys Contact Event will be sent to a banker to follow up with the client using. Refer to the Conversation Starters tab to promote a successful call with the client. Once the necessary BSA information is obtained, record call results. BSA requests you attempt to contact the client 3 times.
To record call results:
- In Xperience > Product > Synapsys CRM > Desktop. The Home/Suite Manager Screen displays.
- Click Events.
- Click Received > Contact List.
- Double click on the new contact event from BSA.
- Refer to the comments section for complete instructions from BSA regarding the reason client contact is required.
- Call the client the same day the contact event is received.
- Update the contact event as follows:
- Summary and Assigned To fields - no changes necessary
- Type - Choose Client Outreach
- Status - update status to Active once client contact is made and information is documented in comments.
- Office - choose your office
-
Outbound Call Reason- Do Not change unless directed by BSA
- BSA –when specific information on recent account activity is required
- BSA – Close Account – use when banker must close the account
- Call Results - Use the drop-down arrow to choose Other – Provide Specifics
-
Comments - Include details from the call providing BSA with the required information.
- Source of funds
- Reason for suspicious activity
- If requested, confirm account has been closed
- If applicable, indicate that a voicemail message was left for the client.
- Tickler - if you are unable to reach the client on your first attempt, set a tickler for the following business day.
- Click Save.
- Click Save and Go Back.
- BSA will update the status to Closed once the requested information is received.
Revenue - BSA Request for Information
When BSA identifies suspicious account activity, a Synapsys Contact Event will be sent to a banker to follow up with the client using. Refer to the Conversation Starters tab to promote a successful call with the client. Once the necessary BSA information is obtained, record call results. BSA requests you attempt to contact the client 3 times.
To record call results:
- In Xperience > Product > Synapsys CRM > Desktop. The Home/Suite Manager Screen displays.
- Click Events.
- Click Received > Contact List.
- Double click on the new contact event from BSA.
- Refer to the comments section for complete instructions from BSA regarding the reason client contact is required.
- Call the client the same day the contact event is received.
- Update the contact event as follows:
- Summary, Assigned To and Type fields - no changes necessary
- Status - update status to Active once client contact is made and information is documented in comments.
- Office - choose your office
-
Outbound Call Reason- Do Not change unless directed by BSA
- BSA –when specific information on recent account activity is required
- BSA – Close Account – use when banker must close the account
- Call Results - Use the drop-down arrow to choose Other – Provide Specifics
-
Comments - Include details from the call providing BSA with the required information.
- Source of funds
- Reason for suspicious activity
- If requested, confirm account has been closed
- If applicable, indicate that a voicemail message was left for the client.
- Tickler - if you are unable to reach the client on your first attempt, set a tickler for the following business day.
- Click Save.
- Click Save and Go Back.
- BSA will update the status to Closed once the requested information is received.
Conversation Starters
Why are you limiting deposits to under $10,000?
Viable answer
- To avoid filing a CTR
- I collect rent once a week which totals $8900 per week. Would you like receipts?
Possibly viable answer (depending on business type)
- My mother will ensure we don't have more than $10,000 in the drawer for security reasons so we deposit often
NOT viable
- That's the way I do it
Increased Frequency of Cash Deposits
Conversation Starter
- "Our client protection team noticed an uptick in the frequency and amount of cash being deposited into our account, can you provide any insight to the source and reason for the activity?”
- “Can you explain why the frequency of every other day movement? Why cash instead of check or electronic transfers? Why moving over to CCB?”
Possible Answers
- “I am 28 years old and I have cash buried in my yard and decided to put a pool in so need to deposit.” Does not answer the question of the source
NOTE: 28 year old's usually don’t bury funds, elder people have been known to.
-
“I received an investment return that was deposited to my Bank of America account and I am moving the proceeds over in cash.”
Does not answer why.
Comfort Client and Defuse Client Defense
Below are examples of client conversations that may assist when clients become defensive of the questions being asked of them and their account activity.
- “With so much elder abuse/ account fraud/ client fraud/ account takeovers, the bank is responsible for monitoring unusual activity to ensure we recognize if anyone is trying to take advantage of you…. We noticed several/ a few/numerous transactions that our monitoring team were concerned about…can you explain the activity?”
- “With so much elder abuse/ account fraud/ client fraud/ account take overs, the bank is responsible for monitoring unusual activity to understand the source and use of funds. We noticed several/ a few/numerous transactions that our monitoring team were concerned about…can you explain the _______________ multiple deposits/withdrawals of cash? (explain meaning the source/ use of the funds?”
- “Our fraud monitoring division questioned a few of your transactions and they have asked me to get clarity to ensure everything is okay and that you are aware of the transactions. I can then assure them you are not being taken advantage of.”
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BANKER: “Our fraud monitoring division questioned a few of your cash deposits/withdrawal patterns and they have asked me to get clarity to ensure everything is okay and why the activity is taking place.
Do you have time for a few questions?” (ask the specific questions supplied by BSA)
Feel free to rely on terms: “We attempt to confirm identified activity within your account to ensure everything appears consistent with your historical transactions and that there isn’t any concern for fraud or other non authorized activity.”
CLIENT: “It’s none of your business. If it is a problem, I will be happy to move my account”.
BANKER: “I understand your need for confidentiality, we don’t intend to offend you in anyway, but we have numerous examples of fraudsters manipulating clients to conduct transactions on their behalf under false pretenses…..we are only trying to protect you. If you are okay with me asking a few questions…(specifically ask the BSA questions)
Recorded Webinar
Click here to access the BSA recorded webinar on this topic.