B*tch Betta Have My Money

[viscousmemories]

I just tried to withdraw some money from my online savings account and got the following email:

Dear ,

As part of your initial application, we did not receive information regarding your current employer, occupation or position. In many cases, this is because you have a status of retired, unemployed or self-employed. We are updating our records as part of our on-going due diligence to be compliant with our standards to support the USA Patriot Act.

Due to the importance of the USA Patriot Act, we have placed a hold on your account(s) until we can document this information for our records. No deposits or withdrawals can be made through your account(s) until we receive this information. We will release the hold upon receipt of this information.

Please provide us with your previous employer, occupation and position by sending an email with this information to fulfillment@fnbodirect.com. If this information is not received within 30 days, the account(s) may be closed. Your immediate attention to this matter is appreciated.

If you wish to discuss this further, please send an email to fulfillment@fnbodirect.com or call 877-370-3707. Please reference your FNBO Direct account number displayed at the top of this page when you contact us.

Thank you for choosing FNBO Direct for your Online Savings Account.

FNBO Direct Customer Service

I've been on hold on their customer service line for about 15 minutes. :brooding:

[livius drusus]

So much for the "if ur not terraist, u have nothink to phear" bullshit.

[ChuckF]

Wow, I feel much safer.

[Ensign Steve]

If this information is not received within 30 days, the account(s) may be closed.

Let them close it. Take your business elsewhere. Like under your matress.

[viscousmemories]

I finally got through to their customer support, and they were frantic. I could hear a bunch of other reps giving the same spiel in the background: Apparently this email was sent to all their customers, regardless of whether there was anything actually wrong with the account. They assured me that my account is fine and that they needed no further information. :phew:

[livius drusus]

Ooh... Man. I wouldn't want to be working in that call center today.

[viscousmemories]

Yeh srsly.

[viscousmemories]

Dear ,

Please disregard the email sent on August 10, 2007, with the subject line: Due Diligence 2nd Request. This email was sent in error and we apologize for the confusion it has caused. If Due Diligence information is required, you will receive a follow-up email. Again we apologize for this inconvenience.

If you have any questions, please send an email to fulfillment@fnbodirect.com or call 877-370-3707. Please reference your FNBO Direct account number when you contact us.

Thank you for choosing FNBO Direct for your Online Savings Account.

Sincerely,
FNBO Direct Customer Service

[Crumb]

Eek, scary shit. :shudder:

[lisarea]

If I were you, I'd cancel anyway.

They froze your fucking account. They did it accidentally this time, but they've left open the possibility they might do it again, on purpose.

[godfry n. glad]

You know why bankers dress all conservative and stuffy, don't you?

It's because they don't want you to know they're doing really scarey stuff with your money.

[D. Scarlatti]

Dear ,

Please disregard the USAPATRIOT Act.

[viscousmemories]

It takes five business days for a transfer of funds anyway, so I wasn't expecting to get the money right away. From the looks of it the account was never actually frozen, I just got a threatening letter. Funnily the first letter actually said "Dear ," like that. The second one had my name.

[vremya]

I used to work as a bank teller during summers in high school. On my first day, when I got to the branch, everyone was frantically running around and the phone was ringing off the hook. It turned out they accidently sent a whole bunch of "You have overdrawn your account for the last time, we're going to close your account, you evil person" letters to people who had just opened accounts. Not the best first impression, for either those customers or me!

[Kyuss Apollo]

It seems they have found out you have been practicing blowing yourself up and flying planes into buildings.

[Ensign Steve]

If I were you, I'd cancel anyway.

They froze your fucking account. They did it accidentally this time, but they've left open the possibility they might do it again, on purpose.

:yeahthat:

The fact that they even have a USA Patriot Act form letter at the ready makes me :shudder:.

Not that I don't bank with one of those evil big box banks with the "hip" television commercials, but my paycheck comes from the government in the first place, so it's not like my money can get any dirtier from there.

[viscousmemories]

Yeah I have to say, it pissed me off that they required my employment info anyway. The only reason the letter was a mistake is 'cause they already collected my employment info when I opened the account. I didn't even notice that it was mandatory at the time.

[Ensign Steve]

Oh, are you seriously? Eff that! Why do they need it?

[viscousmemories]

Apparently it's used to ensure that I'm a True Patriot™.

[Ensign Steve]

Where do the ACLU lawyers invest their money? :?

[Cynical-Chick]

Where do the ACLU lawyers invest their money? :?
Local credit unions? I can name 3 local ones in about 5 seconds.

My bank doesn't advertise, as far as I can tell.

[Ensign Steve]

Local credit unions aren't subject to the Patriot Act? That's good news.

[lisarea]

Local credit unions aren't subject to the Patriot Act? That's good news.

Well, unless I'm missing a big part, the Patriot Act doesn't have specific requirements for employment verification. So the bank lied. Companies are always trying to pass off their odious policies as laws, though.

IIRC, all that's specifically required under the Patriot Act is basic verification of the account holder's identity and address, and I think there are some other vague requirements if an account is showing suspicious activity.

Generally, local credit unions are less likely to do shit like make up fake Patriot Act requirements so they can fuck around with you and freeze your account.

[viscousmemories]

Yeah, this seems to be the relevant bit (from here (http://www.fincen.gov/312factsheet.html)):

(3) What are the general due diligence requirements of the private banking portion of the final rule?

U.S. financial institutions covered by the final rule are required to establish and maintain a due diligence program that includes policies, procedures, and controls that are reasonably designed to detect and report any known or suspected money laundering or suspicious activity conducted through or involving any private banking account that is established, maintained, administered, or managed in the United States.

Specifically, financial institutions covered by the final rule must take reasonable steps to: (1) determine the identity of all nominal and beneficial owners of the private banking account; (2) determine whether any such owner is a senior foreign political official and, thus, is subject to enhanced scrutiny (described below); (3) determine the source(s) of funds deposited into the private banking account and the purpose and expected use of the account; and (4) review the activity of the account to ensure that the activity is consistent with the information obtained about the source of funds, the stated purpose and the expected use of the account, as needed to guard against money laundering, and to report any suspicious activity.

[ShottleBop]

The governing regulations require banks to require certain minimum information, but also require each institution to develop a Customer Identification Program that is tailored to its circumstances. This is the relevant portion of 31 CFR Part 103:
(b) Customer Identification Program: minimum requirements--
(1) In general. A bank must implement a written Customer Identification Program (CIP) appropriate for its size and type of business that, at a minimum, includes each of the requirements of paragraphs (b)(1) through (5) of this section. If a bank is required to have an anti-money laundering compliance program under the regulations implementing 31 U.S.C. 5318(h), 12 U.S.C. 1818(s), or 12 U.S.C. 1786(q)(1), then the CIP must be a part of the anti-money laundering compliance program. Until such time as credit unions, private banks, and trust companies without a Federal
functional regulator are subject to such a program, their CIPs must be
approved by their boards of directors.

(2) Identity verification procedures. The CIP must include risk-based procedures for verifying the identity of each customer to the extent reasonable and practicable. The procedures must enable the bank to form a reasonable belief that it knows the true identity of each customer. These procedures must be based on the bank's assessment of the relevant risks, including those presented by the various types of accounts maintained by the bank, the various methods of opening accounts provided by the bank, the various types of identifying information available, and the bank's size, location, and customer base. At a minimum, these procedures must contain the elements described in this paragraph (b)(2).

(i) Customer information required--(A) In general. The CIP must contain procedures for opening an account that specify the identifying information that will be obtained from each customer. Except as permitted by paragraphs (b)(2)(i)(B) and (C) of this section, the bank must obtain, at a minimum, the following information from the customer prior to opening an account:
(1) Name;
(2) Date of birth, for an individual;
(3) Address, which shall be:
(i) For an individual, a residential or business street address;
(ii) For an individual who does not have a residential or business
street address, an Army Post Office (APO) or Fleet Post Office (FPO) box number, or the residential or business street address of next of kin or of another contact individual; or
(iii) For a person other than an individual (such as a corporation,
partnership, or trust), a principal place of business, local office, or
other physical location; and
(4) Identification number, which shall be:
(i) For a U.S. person, a taxpayer identification number; or
(ii) For a non-U.S. person, one or more of the following: a taxpayer
identification number; passport number and country of issuance; alien identification card number; or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard.

Note to paragraph (b)(2)(i)(A)(4)(ii):
When opening an account for a foreign business or enterprise that does not have an identification number, the bank must request alternative government-issued documentation certifying the existence of the business or enterprise.

(B) Exception for persons applying for a taxpayer identification number. Instead of obtaining a taxpayer identification number from a customer prior to opening the account, the CIP may include procedures for opening an account for a customer that has applied for, but has not received, a taxpayer identification number. In this case, the CIP must include procedures to confirm that the application was filed before the customer opens the account and to obtain the taxpayer identification number within a reasonable period of time after the account is opened.

(C) Credit card accounts. In connection with a customer who opens a credit card account, a bank may obtain the identifying information about a customer required under paragraph (b)(2)(i)(A) by acquiring it from a third-party source prior to extending credit to the customer.

(ii) Customer verification. The CIP must contain procedures for verifying the identity of the customer, using information obtained in accordance with paragraph (b)(2)(i) of this section, within a reasonable time after the account is opened. The procedures must describe when the bank will use documents, non-documentary methods, or a combination of both methods as described in this paragraph (b)(2)(ii).
(A) Verification through documents. For a bank relying on documents, the CIP must contain procedures that set forth the documents that the bank will use. These documents may include:
(1) For an individual, unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, such as a driver's license or passport; and
(2) For a person other than an individual (such as a corporation, partnership, or trust), documents showing the existence of the entity, such as certified articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument.
(B) Verification through non-documentary methods. For a bank relying on non-documentary methods, the CIP must contain procedures that describe the non-documentary methods the bank will use.
(1) These methods may include contacting a customer; independently verifying the customer's identity through the comparison of information provided by the customer with information obtained from a consumer
reporting agency, public database, or other source; checking references
with other financial institutions; and obtaining a financial statement.
(2) The bank's non-documentary procedures must address situations where an individual is unable to present an unexpired government-issued
identification document that bears a photograph or similar safeguard; the bank is not familiar with the documents presented; the account is opened without obtaining documents; the customer opens the account without appearing in person at the bank; and where the bank is otherwise presented with circumstances that increase the risk that the bank will be unable to verify the true identity of a customer through documents.
(C) Additional verification for certain customers. The CIP must address situations where, based on the bank's risk assessment of a new account opened by a customer that is not an individual, the bank will obtain information about individuals with authority or control over such account, ncluding signatories, in order to verify the customer's identity. This verification method applies only when the bank cannot verify the customer's true identity using the verification methods described in paragraphs (b)(2)(ii)(A) and (B) of this section.
(iii) Lack of verification. The CIP must include procedures for responding to circumstances in which the bank cannot form a reasonable belief that it knows the true identity of a customer. These procedures should describe:
(A) When the bank should not open an account;
(B) The terms under which a customer may use an account while the bank attempts to verify the customer's identity;
(C) When the bank should close an account, after attempts to verify a customer's identity have failed; and
(D) When the bank should file a Suspicious Activity Report in accordance with applicable law and regulation.
(3) Recordkeeping. The CIP must include procedures for making and maintaining a record of all information obtained under the procedures implementing paragraph (b) of this section.
(i) Required records. At a minimum, the record must include:
(A) All identifying information about a customer obtained under paragraph (b)(2)(i) of this section;
(B) A description of any document that was relied on under paragraph
(b)(2)(ii)(A) of this section noting the type of document, any identification number contained in the document, the place of issuance and, if any, the date of issuance and expiration date;
(C) A description of the methods and the results of any measures undertaken to verify the identity of the customer under paragraph (b)(2)(ii)(B) or (C) of this section; and
(D) A description of the resolution of any substantive discrepancy discovered when verifying the identifying information obtained.
(ii) Retention of records. The bank must retain the information in paragraph (b)(3)(i)(A) of this section for five years after the date the account is closed or, in the case of credit card accounts, five years after the account is closed or becomes dormant. The bank must retain the information in paragraphs (b)(3)(i)(B), (C), and (D) of this section for
five years after the record is made.

(4) Comparison with government lists. The CIP must include procedures for determining whether the customer appears on any list of
known or suspected terrorists or terrorist organizations issued by any
Federal government agency and designated as such by Treasury in
consultation with the Federal functional regulators. The procedures must
require the bank to make such a determination within a reasonable period
of time after the account is opened, or earlier, if required by another
Federal law or regulation or Federal directive issued in connection with
the applicable list. The procedures must also require the bank to follow
all Federal directives issued in connection with such lists.

(5)(i) Customer notice. The CIP must include procedures for
providing bank customers with adequate notice that the bank is
requesting information to verify their identities.
(ii) Adequate notice. Notice is adequate if the bank generally
describes the identification requirements of this section and provides
the notice in a manner reasonably designed to ensure that a customer is
able to view the notice, or is otherwise given notice, before opening an
account. For example, depending upon the manner in which the account is
opened, a bank may post a notice in the lobby or on its website, include
the notice on its account applications, or use any other form of written
or oral notice.
(iii) Sample notice. If appropriate, a bank may use the following
sample language to provide notice to its customers:

IMPORTANT INFORMATION ABOUT PROCEDURES FOR OPENING A NEW ACCOUNT

To help the government fight the funding of terrorism and money
laundering activities, Federal law requires all financial institutions
to obtain, verify, and record information that identifies each person
who opens an account.
What this means for you: When you open an account, we will ask for
your name, address, date of birth, and other information that will allow
us to identify you. We may also ask to see your driver's license or
other identifying documents.

Banks can vary as to what their Customer Identity Programs require. The sample Customer Identity Program (www.bankerscompliance.com/assets/ files/documentation/CIP_Procedures.pdf) available at the website of Banker's Compliance Consulting (http://www.bankerscompliance.com/), for example, notes: These customer identification program (CIP) procedures were developed for a hypothetical bank and are for illustration purposes only. These procedures do not follow Section 326 rules exactly. Feel free to use these procedures as an example to help you
develop your institution’s procedures. These procedures should not be adopted in their entirety. Section 326 is risk based. Thus, each institution’s CIP will differ according to the level of risk associated with an institution’s size, geographic location, customer base, account types, method of opening accounts, etc.

Verifying employment is identified as one non-documentary way of verifying a customer's identity.