Consumer Reports: What Information Furnishers Need to Know | Federal Trade Commission
Adding a Screening Service to a In the User Sign In page, users must also provide a user name and 21 is processed, the system will fail and will display a message to .. is no special indicator. The Check for Duplicate action in the Recruiting Center allows users to verify if a candidate already. The following sections provide more details about the SIP PRI Gateway. When the system attempts a SIP call to a user in the PRI domain, the .. This enables the alarm indicators on the breaker interface panel to be .. “Clearing the Motorola Ethernet connection failure” on When checked, this field only allows. A. At your request, TransUnion will verify any credit information disputed by you. TransUnion Consumer Relations Department Signs of Fraud can vary but typical indicators of fraud and / or stolen identity include: .. In the course of providing these services, TransUnion may use personal information contained in the.
This screening is done prior to the approval of a new FRFI and when ownership interests change. Over the past few years, Canada has implemented several new economic and anti-proliferation of weapons of mass destruction sanctions against a number of countries, entities and designated persons. In addition, the FATF has issued guidance documents on a number of these and related matters. The array of obligations imposed on FRFIs by the reporting requirements, sanctions and related procedural actions merits dealing with designated name searching, listings, reporting, economic and anti- proliferation sanctions in a separate Guideline.
FRFIs should consult the appropriate guidance issued by these bodies for more information on risk assessment and effective controls. Examples of regulatory requirements include: Some requirements feed into broader outcomes; others are themselves outcomes.
Deterring and Detecting Money Laundering and Terrorist Financing
In all cases, the manner in which these outcomes may be achieved is prescribed. By one or more Prescriptive Measures In these situations, one or more measures are prescribed.
All of the prescribed measures must be followed. By a choice of Prescriptive Measures In these situations, a choice of alternative measures is prescribed. These measures offer FRFIs flexibility in achieving the prescribed outcome.
Aside from selecting which option to choose, no other options or alternatives are available to the FRFI. Examples include prescribed types of acceptable identification documentation for individuals and prescribed sets of alternative measures for the identification of credit card clients in non-face-to face situations. To be reasonable, the measures used must achieve the prescribed outcome.
Wealth Screening: The Definitive Guide
An example is reasonable measures to determine the source of funds for certain high risk clients. This Guideline identifies measures that OSFI has found to be reasonable when applied effectively — i. The measures, which are drawn from a wide base of sources, including the FATF, should not be treated as checklists.
As a general principle, the corporate standard should be consistent with Canadian regulatory requirements Footnote 8. FRFIs should ensure that unless there is an explicit prohibition, such standards are applied. Senior Management should ensure that: In smaller FRFIs, where functional segregation may be difficult to achieve, compensating controls should be established to meet this goal.
Consideration should be given to outsourcing the CAMLO function if compensating controls are not practical or possible. This will support the goal of assessing overall adequacy and effectiveness. Reasonable measures to achieve this could include: For the purposes of item iv above, FRFIs should take into account transaction risk factors, for example, structured or otherwise complex transactions, and factors that may fall into more than one of the other three categories.
Assessment of inherent risks refers to a process that: In considering ML and TF risks, consideration should be given to what, if any, pertinent changes have occurred since the assessment of inherent risks was last performed. Reasonable measures to accomplish this could include: Regular assessment of inherent ML and TF risks enables FRFIs to tailor or adjust corporate control measures to identified risk, which in turn facilitates the allocation of more risk management resources to areas of greater vulnerability.
The following sections discuss the methodology and desired outcomes of the process used to analyse inherent ML and TF risks. The outcome of the methodology should be a rational, well-organized and well-documented inherent risk analysis. Reasonable measures to include in the methodology used would include consideration of: In each category, OSFI has indicated types of risks. Categories of clients that may indicate a higher risk could include: Money services businesses for example, remittance houses, foreign exchange businesses, money transfer agents, bank note traders, cash couriers or other businesses offering money transfer or movement facilities ; Casinos, betting and other gaming-related businesses; Businesses that, while not normally cash-intensive, generate substantial amounts of cash for certain lines of activity; and charities and other non-profit organizations that are not monitored or supervised for example, not registered with CRA.
Categories of business relationships that may indicate a higher risk could include: Categories of products and services that may indicate a higher risk could include: Categories of delivery channels that may indicate a higher risk could include: This is risk associated with places in which FRFI activities are carried out. Where FRFIs have subsidiaries or branches in such places, this may mitigate or elevate the risk.
Categories of countries that indicate a higher risk include countries: FRFIs should ensure that they take any other relevant factors into consideration in an inherent risk assessment, including transaction risk factors and combinations of factors that may fall within more than one of the other three categories.
Rating and Ranking An appropriate methodology should assign appropriate ML and TF risk levels to the pertinent activities of the FRFI and in so doing, identify the higher risks to which enhanced due diligence and ongoing monitoring must be applied. The criteria used for rating and ranking should have a rational basis in ML and TF risk and address ML and TF risk factors that are unique to specific business lines, areas and jurisdictions, and also more general risk factors.
Finally, the methodology should enable FRFIs to comply with the regulatory requirement to identify higher risk clients activity Footnote 14 for purposes of establishing a threshold level of enhanced due diligence that is appropriate in the circumstances. Using Assessment of Inherent Risks as the Basis for Risk Controls Results of the assessment of inherent risks should inform the development of risk controls, and the allocation of resources, commensurate with levels of ML and TF risk in the enterprise.
Certain risk control measures are prescribed by regulatory requirements. These cannot be qualified or bypassed by inherent risk assessments. They include, for example: FRFIs should ensure that control policies and procedures are kept up to date to mitigate risks.
They must also comply with other regulatory requirements: Control policies and procedures should be embedded in business areas commensurate with the risks they are intended to mitigate, and otherwise tailored to the particular circumstances in which they operate. Policies setting a corporate standard should be approved by Senior Management and implemented consistently across the enterprise.
They should establish clear and definitive requirements throughout the organization. Policies should also reflect that unless there is an explicit prohibition, the corporate standard, at least, should be applied. It should be noted that differences in local market conditions are not a sound basis for lowering or eliminating enterprise standards. Examples of topics that should be covered by policies are: Therefore, it is essential that procedures state clearly what actions are to be taken, by whom, where and when noting pertinent regulatory deadlines as appropriate.
These components must comply with applicable regulatory requirements, and must be enhanced for higher risk situations Footnote As a general principle, a business relationship should only be entered into or maintained with a client if the FRFI is satisfied that the information it has gathered demonstrates that the FRFI knows the client i.
DTIs are required to keep a record of the intended use of each account opened, other than a credit card account Footnote If FRFIs provide services such as account numbering or coding services that effectively shield the identity of a client for business reasons for instance, in a corporate acquisition where the premature circulation of information could jeopardize the transactionor where client identity is withheld for proprietary reasons, FRFIs must ensure that they have appropriately ascertained the identity of the client and that this information is accessible by the CAMLO.
Where the regulatory requirements prescribe a determination of the status of a client, for example, the determination of whether a client is a PEFP, there must actually be a determination and FRFIs should ensure that a determination is made based on an assessment of the information received.
Nature and Amount The nature and extent of CDD measures should be appropriate for the nature of, and proportional to the level of, the ML and TF risk that is posed by the client in the circumstances. CDD standards should provide that where there are doubts Footnote 20 about the veracity or adequacy of previously obtained client identification and verification data, enhanced CDD must be performed.
The level of such enhanced due diligence should be sufficient to mitigate the inconsistencies, uncertain or doubtful results. FRFIs should ensure that if such clients subsequently purchase products to which client identification requirements apply, they are subject to appropriate client identification measures. Reasonable measures to ensure that such clients are appropriately identified could include: The PCMLTFR specifies the originals of prescribed valid documents or types of valid documents that may be inspected to ascertain the identity of individuals and the existence of entities in face to face and non face to face scenarios, and the timing for doing so.
While identification and verification standards and policies must meet the minimum prescribed requirements, FRFIs may consider that the assessment of inherent risk justifies the application of additional identification requirements to some categories of client. These include, inter alia, birth certificates. Where a birth certificate or a SIN card is the only document available to ascertain identity, and the assessed ML or TF risk of the client is other than minimal, FRFIs should consider applying additional identification measures.
Such additional measures could include viewing the original of other acceptable government-issued identification documents, including government-issued photo identification, or, if these are not available, other credible evidence supporting the identity of the client such as a property tax or utility bill. For persons without acceptable Canadian identification documents, comparable or equivalent foreign identification documents may be acceptable if they can be read and assessed as valid identification documents for example, by reference to publicly available information and can be understood by the FRFI.
Identifying a client that is a corporation or other entity may involve the collection of substantial information in some cases. Reasonable measures to obtain this information could include: Where a FRFI is required to obtain the occupation of a person for example, a director of a client entitythe FRFI should ensure that the occupation obtained is the person's principal occupation and not merely the person's title in the client entity.
The measures applied should be commensurate with the level of assessed risk. DTIs must also ascertain the identity of every person who signs a signature card in respect of a business account, except that where the signature card is signed by more than three authorized individuals, the identities of at least three of them must be ascertained Footnote The requirements of identification of individual clients are applicable.
Life insurance companies should adopt a similar practice as a matter of prudent risk management because the inherent risk of not identifying signing officers for business accounts is similar. Reasonable measures could include: For these situations, life insurance companies should therefore develop and implement policies and procedures designed to ensure that: In this case, the date of delinquency is March The date that the creditor places the account for collection is not the basis for calculating the delinquency date.
Mary makes partial payments for the next five months, but never brings the account current. The creditor places the account for collection in January Because the account was never brought current during the period partial payments were made, the delinquency that immediately preceded the collection began in Aprilwhen Mary first became delinquent.
The correct delinquency date is April The account is placed for collection with Collector A on April 1, Collection is not successful.
How to change screening indicator on UC - Cisco Community
The creditor places the account with Collector B in February The date of the delinquency for reporting purposes is December Repeatedly placing an account for collection or using different collectors does not change the delinquency date. The creditor has never reported the date of the delinquent account to the CRAs, but has records indicating the date of delinquency as November A debt collector acquires the debt and attempts collection.
If the debt collector establishes and follows reasonable procedures to learn the date of delinquency from the creditor — and finds that November is the delinquency date — the debt collector may report that date to the CRAs as the delinquency date. The account is placed for collection in November If the debt collector establishes and follows reasonable procedures to ensure that the delinquency date reported precedes the date the account is placed for collection, charged to profit or loss, or subjected to any similar action by the original creditor, the debt collector may report that alternate delinquency date to a CRA.
In this case, the alternate delinquency date must be before November FCRA a 5 B iii Negative Information from Financial Institutions — If you are a financial institution as defined in the Gramm-Leach-Bliley Act that extends credit and regularly reports Anegative information about your customers to a nationwide CRA for example, Equifax, Experian, or TransUnionyou must notify your customers that you report such negative information.2011 Updated PIH-EIV System 9.2.1 Training: Day 2, Part 2 - HUD - 10/28/11
Examples of negative information include a customer's delinquencies, late payments, insolvency, or any form of default. FCRA a 7 G i You must provide the notice either before you furnish the negative information or within 30 days of furnishing it. You may include the notice with a notice of default, a billing statement, or another item sent to the consumer, but you cannot send it with a Truth In Lending Act notification. The notices must be clear and conspicuous.
Medical Information — If your primary business is providing medical services, products, or devices, and you, your agent, or your assignee reports information about consumers to CRAs, you must notify each CRA that you are a medical provider. Consumers may dispute information that you furnished in two ways: They may submit a dispute to the CRA. They may submit a dispute directly to you. Normally, this is 30 days after the CRA gets the dispute from the consumer. The CRA must give you all the relevant information it gets within five business days of receipt, and must promptly give you additional relevant information provided by the consumer.
For example, disputes relating to whether there is or has been identity theft or fraud against the consumer, whether there is individual or joint liability on an account, or whether the consumer is an authorized user of a credit account; the terms of a credit account or other debt with you.
For example, disputes relating to the type of account, principal balance, scheduled payment amount on an account, or the amount of the credit limit on an open-end account; the consumer's performance or other conduct concerning an account or other relationship with you. For example, disputes relating to the current payment status, high balance, date a payment was made, amount of a payment made, or date an account was opened or closed; or any other information in a consumer report about an account or relationship with you that affects the consumer's creditworthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or lifestyle.