06.08 – High Value Accounts Exceptions to Paper Record Search

A Financial Institution must review its electronically searchable data for High Value Accounts in the same manner as for its Lower Value Accounts.

Also, a paper record search is required for accounts with an aggregated balance of over $1,000,000. However, this will not be required where the following information is electronically searchable:

  • the Account Holder’s residence address and mailing address currently on file with the Reporting Financial Institution;
  • whether there is a current “in-care-of” address or “hold mail” address for the Account Holder;
  • whether there is any power of attorney or signatory authority for the account; and
  • in the case of Financial Accounts other than Depository Accounts whether there are standing instructions to transfer funds in the account to another account (including an account at another branch of the Reporting Financial Institution or another Financial Institution).

If the Financial Institution maintains a system where it can electronically verify that they do not hold this information (i.e. it is possible to positively confirm that the Account has no standing instructions), then that information is held to be electronically searchable. In cases where only some of the information is electronically searchable the Financial Institution will only have to undertake a paper record search in respect of the areas where the information is not electronically searchable.

Example

A Financial Institution maintains High Value Accounts. The Account Holder’s residence, mailing, “in-care-of”, and “hold mail” addresses for the Account Holder as well as the standing instructions to transfer funds are all electronically searchable. However, any power of attorney or signatory authority details for the account are held in the paper master file.

In this case, only the power of attorney or signatory authority details will be subject to paper review.