This weekly report, e-mailed from Deposit Services, details all errors pertaining to new and revised account documentation. Tabs are included for Document Exception Report (DER), DER Client Identification Program (CIP), Verafin errors, Closing the Account, and DER Extension and Exception procedures. Errors must be corrected as soon as possible and, if not corrected by the Closing Date, require the clients account to be closed for missing or incorrect information and/or documentation.
A daily e-mail will be sent out to any associate with exceptions on the weekly report. The e-mail will detail the error. The e-mail will be sent until the error is corrected.
Note: All items on the DER for longer than 2 weeks are reflected in an associates performance appraisals.
DER Report
Missing or incorrect documentation will appear on this report as soon as identified. Document errors including incorrect ownership category, ownership and/or rights at death not initialed, missing signatures, and business document errors are described in the Exception Type columns.
Items MUST be resolved within 30 days from the date the item appears on the report.
- DER items highlighted in yellow are 20-30 day exceptions.
- These accounts require IMMEDIATE attention. You MUST submit a Request for Extension or close the account prior to the Closing Date indicated on the report.
- Account(s) listed on the report 31 days or greater are highlighted in red.
- These accounts MUST have an approved extension on file prior to the 35th day or the account(s) must be closed.
DER.CIP Report
Document exceptions and client identification exceptions occur when insufficient or incorrect information and/or documentation is obtained at account opening or account revision. These exceptions are to be cleared within 14 days. The Document Exception Report (DER) and Client Identification Program (CIP) report is a monthly report that details all occurrences that exceeded the 14 day grace period by office and associate.
This report is used for coaching and performance development.
View report from File Explorer > Operations J: Drive > Lead Teller > Reporting > DER.CIP Weekly Reports
Missing or incorrect documentation appears on the report as soon as identified. CIP errors including the following are described in the Exception Type columns:
- Date of birth
- Missing or incomplete primary or secondary identification
- IRS Address (P.O. Boxes are NOT acceptable)
- ITS TIN/Name Mismatch not corrected when an account is opened or revised that is linked to the CIF with the IRS TIN/Name Mismatch
Items MUST be resolved within 30 days from the date the item appears on the report or the Bank Secrecy Act (BSA) Department will require the account be closed.
- CIP errors are to be corrected at the office level and are removed from the CIP Report systematically once corrected.
Verafin
Missing information or failure to complete the Client Due Diligence (CDD) Questionnaire in Verafin. This information is required by federal regulations to be obtained and can have a negative impact on the bank when not completed.
Items MUST be resolved within 30 days from the date the item appears on the report or BSA will require the account be closed.
- Associates are required to contact clients in a timely manner for completion of the CDD questionnaire in Verafin.
- Associates are NOT to complete a questionnaire based on how they feel a client will respond.
- For business clients, if you are unable to complete the questionnaire by phone or appointment, the Client Due Diligence Questionnaire - Business can be emailed to the client for completion. Once returned, the questionnaire can be completed in Verafin.
For assistance in reducing these errors and for step by step instructions see the following articles:
- Client Due Diligence Questionnaire-Verafin
- Personal CDD Questionnaire
- Sole Proprietor CDD Questionnaire
- Business CDD Questionnaire
Closing the Account - Unresolved within 30 Days
The opening associate is responsible for sending out the 10-day closing letter and then closing the account if the issue is not resolved. Regional Experience Managers (RXM) and Revenue Management will be responsible for reviewing this report and ensuring the missing documents are received or the accounts are closed.
A specific 10-Day Closing Letter is used for this purpose. This letter is to be sent on the 30th day, and the account must be closed by the 40th day if missing or incorrect documentation is not received.
If the account was opened for a business partner, provide a copy of the letter to them.
DER Extension & Exception
When an account has been placed on the Document Exception Report (DER) due to missing or incomplete documents, the items must be cleared as soon as possible but no later than 30 days.
DER Extension
In certain cases, an extension is necessary. Extensions are limited to 30 days. The extension requires approval from Deposit Services.
The associate appearing on the DER report is required to discuss the need for an extension with their Client Experience Manager/Direct Banking Manager/Supervisor, explaining the reason for an extension request.
- Complete the DER Document Extension Request form.
- E-mail the completed form to _Deposit Svc - DER for review and approval.
- Once reviewed and approved Deposit Services e-mails the approved form back to the requesting associate, who then must submit the form for imaging to the account.
- Deposit Services updates the DER report indicating the name of the approving officer and the new close date.
- If not corrected by the new close date, the account must be closed immediately
DER Exception
In certain cases, an exception is necessary. The exception requires approval from Deposit Services.
The associate appearing on the DER report is required to discuss the need for an exception with their Client Experience Manager/Direct Banking Manager/Supervisor, explaining the reason for an exception request.
- Complete the DER Document Exception Request form.
- E-mail the completed form to _Deposit Svc - DER for review and approval.
- Once reviewed and approved Deposit Services e-mails the approved form back to the requesting associate, who then must submit the form for imaging to the account.
- Deposit Services updates the DER report indicating the name of the approving officer and the new close date.
New Account Document Exception
The DER New Account Document Exception form must be used when a business partner requests an account to be opened without all of the required documentation.
The business partner is required to sign the form, along with the Community President, acknowledging that the account will be closed if the missing required documentation is not received and scanned within 30 days.
Justification for Extension and Exception Request
Consider the following:
- What efforts have been made so far to collect the required documentation (dates/method/results)?
- Why has the client been unable to provide the required documentation (For example: unavailable documentation and/or client, the client needs more time to obtain the documentation, or the client is unresponsive or uncooperative)?
- Reason(s) additional time is needed to obtain the required documentation.
For questions or further research contact Call Me Direct at ext. 397100.