for those that want the quick version, section 6 is the operative part of the regs (page 44). My view is that the examples of appropriate policies and procedures are so broad that they are worthless. Its basically the Treasury saying that an appropriate procedure would be one that provides reasonable due diligence to know your customer.....so it just begs the question and tosses the issue back to the banks. I imagine the banks will comment heavily on this claiming that it is way too vauge....I also love that the implementation time is estimated at 25 hours. I'd like to see ANY procedure that is established by a bank that only takes 25 man hours to implement....
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