103000 – Due Diligence: Pre-Existing Individual Accounts: High Value Accounts: Relationship Manager Inquiry: Examples
The following examples illustrate when an employee of financial institution would be regarded as a relationship manager:
An individual holds a Custodial Account with a financial institution. The value of the account at the end of the appropriate reporting period is an amount equivalent to US$1,350,000. An employee of the financial institution has a role that requires them to manage the account on an ongoing basis and maintain the financial institution’s relationship with the individual Account Holder. As the account has value over US$1million, the employee will be a relationship manager for this account.
An individual holds a Custodial Account with a financial institution with a value at the end of the appropriate reporting period of an amount equivalent to US$780,000. Also, the individual also has a Depository Account with the financial institution with a balance at the same date of an amount equal to US$427,000. The financial institution’s internal systems link the accounts to the same Account Holder; thus the accounts must be aggregated, the total balances exceed US$1million so belong to a High Value Account Holder. The relationship with the Account Holder is managed in a similar way to that in example 1 above. The employee with that role will be a relationship manager in respect of the accounts held by this Account Holder.
The facts are the same as in example 2 except that the employee has no direct contact with the Account Holder merely performing an administrative role in relation to the accounts. Here the employee is not a relationship manager.