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CDD Team Training – Don’t Skip A Beat

February 13, 2018
Read Time: 0 min

CDD team training rap

Bust Out a Beat for Beneficial Ownership In Your Next CDD Team Training

With the CDD Final Rule mandatory compliance date quickly approaching, there is a lot of anxiety around all of the changes that need to be made. In a time of uncertainty, one of our customers went above and beyond and took her staff training on the new CDD Rule  to the next level. Anita Garrett, CRCM of First National Bank of Layton wrote a rap to teach her staff all they need to know about the changes they can expect come May 11th. We admire her for her hard work, creativity and bringing out the fun in beneficial ownership. Below is Anita’s CDD Rap. 

The Customer Due Diligence (CDD) Rap

I’m goin’ to tell you the facts about CDD.
About “beneficial ownership” specifically.
It’s about the human who controls or who owns,
Each entity involved at the outset of a loan.

It also applies to a deposit account,
Where the biz is trusting you with money you can count.
A safe deposit box and cash management too,
These and other accounts are where you need to come through.

If this law you choose to forget and/or neglect,
You will forever be in the zone of compliance torment.

CDD has two prongs that you cannot ignore:
Control and also ownership. They can be a chore.
Do CIP on the one mister or the miss,
Who governs the business and whose feet all want to kiss.

Those who own a quarter or more piece of the pie,
Must too be in your sights as one to identify.
If they in any way have a stake in the game,
You must do CIP or on your head lies the blame.

If you fail to adhere to this timely subject,
You will forever be in the zone of compliance torment.

When the account is launched you must have rectified,
Who these human souls are and you cannot let it slide.
Get a certificate from one who’s at the meet.
If you forget this step, it is you who takes the heat.

Upon this evidence you know you can rely,
Unless you know other facts that make you testify,
That all that is bogus and makes you shout “Say what?”
You must dig deeper until you feel good in your gut.

If this law you choose to forget and/or neglect,
You will forever be in the zone of compliance torment.

This does not apply to the existing accounts,
Except when something hokey would make you want to pounce.
When material changes in B.O. occur,
Back to this trendy rap song you should plan to refer.

Do OFAC and PEP scans for each one on the list,
And doc the file well so you know it won’t be missed.
The sad news I leave you with – and it’s paramount:
You need to repeat this song for every new account.

If you fail to adhere to this timely subject,
You will forever be in the zone of compliance torment.

[Drop the Mic]

by Anita Garrett, CRCM
SVP, Sr. Compliance Officer
First National Bank of Layton
Written: 2/8/2018

 

Learn More

Here are 5 Way To Ensure Adoption – Prepare Your Front Line For Beneficial Ownership

Banker’s Toolbox can help you navigate the new regulation and get you up and running before the mandatory compliance date, with the Beneficial Ownership Readiness Plan. For more information about Banker’s Toolbox CDD/EDD software, Due Diligence Manager visit our product page or speak with one of our experts.

 

About Abrigo

Abrigo enables U.S. financial institutions to support their communities through technology that fights financial crime, grows loans and deposits, and optimizes risk. Abrigo's platform centralizes the institution's data, creates a digital user experience, ensures compliance, and delivers efficiency for scale and profitable growth.

Make Big Things Happen.

 

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