BSA Compliance: Third-Party 314(a) Searches

Do you rely on a third party or your core processing vendor to conduct your 314(a) searches?

If yes, are you logging into FinCEN’s Secure Information Sharing System (SISS) and downloading each 314(a) list so the third party/core processor can run it against your customer records?

Find all your BSA Resources HERE!

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BSA Compliance: Third-Party 314(a) Searches

If you rely on a third-party/core processor to download the 314(a) lists on your behalf, you likely have a problem. While you can rely on them to run the searches against your customer records, each individual bank MUST still have a 314(a) contact person, and each bank/contact MUST log into FinCEN’s SISS themselves in order to download the 314(a) lists.

The issue is not necessarily that banks could receive different 314(a) lists.  FinCEN confirmed that the same list is generally provided to all banks.  The only time a list “may” differ is IF there’s a targeted, special list that pertains to a specific area. That said, we are not aware of any such targeted lists.

This issue is that you cannot allow a third party to download the lists that it receives from FinCEN, on your behalf. EACH bank MUST log in and download their own 314(a) lists. We don’t see a lot of issues with this but It might be a good idea to verify that you have a contact person in your bank, that they are receiving the communications from FinCEN and THEY are logging in to download the 314(a) lists.

Find BSA Resources Here

Published
2021/04/06
David Dickinson

David Dickinson

David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.

He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.

David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.

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