MM2H Update: Reconsidering Thailand; Visa issues intensify

Financially speaking, moving from the USA to Canada in 2001 was a very smart move, assuming the bulk of your assets were in US Dollars. Luckily, Diane and I left California for Calgary soon after we met during the weakest stretch for the Canadian Dollar in over 50 years. Exchanging one dollar meant receiving back almost $1.58, saving us almost $20,000 on the down payment of our first house. Conversely, when we sold the house for double what we paid only six years later and moved back to California, the Loonie (Canada’s currency) strengthened so much that we received about $0.93 US back for every $1.00 Canadian. Had it remained the same, it would barely have made sense to sell.

stacks-of-red-tapeRecently, I posted about the Malaysian ministry enforcing stricter income verification policies for MM2H applicants that might potentially spell trouble for Americans. Issued as a ten-year social visit pass renewable indefinitely, the MM2H is an attractive long-term visa not requiring any “visa runs” like neighboring Thailand, albeit with more paperwork and much larger financial requirements. Navigating the tedious procedure and emailing Joy-Stay, (our agent) for six months now, I’m thinking we may have finally hit a patch of bad timing through no fault of our own. Almost too coincidentally, an ambiguously written notice from Bank of America arrived last week describing what sounds like a mass consolidation of bank branches that might be a nail in the coffin for the ministry’s “verification letter” from our financial institution.

In a nutshell, the issue involves the 14th item on a checklist of 26 tedious conditions required for submission of an application. The ministry requires proof of steady income totaling MYR 10,000 per month (about $3,450 USD). Ironically, the visa does NOT let an applicant work in Malaysia meaning they eliminate this condition upon approval. Even odder, only wealthy people with enormous interest income or holders of large pensions could satisfy the “income requirement” without using current salary or perhaps self-employed business income. Ideal for overseas applicants about to retire like us, they will allow an applicant to use their spouse’s salary as long as it’s deposited into a joint account and since I’ve been a house husband for one year now, we are using Diane’s salary on our application.

What banks looked when they gave out client information to anyone

What banks looked like when they gave out client information to anyone who asked

Proving the income is another issue. Requiring three months of bank statements and salary slips that match the relevant income, the ministry wants original statements” or certified true copies”. Initially planning on using the second option, a notary working for Diane’s company informed us it’s illegal in California to notarize anything for use as a “certified true copy” except special legal documents. Explaining this to Joy-Stay, I moved on to option one but found out there is no such thing as “original statements” anymore since everything related to finances in the USA is electronic.

maybe this seal will work

maybe this seal will work

Harkening back to the good old days, the ministry likes to see high glossy paper statements with pretty graphs, colors and even an “official bank seal”. Informing me my only option was printing my own statements at home because all Bank of America’s branches have had color printers removed for cost purposes, I grew frustrated and wasted $60 on a Canon ink jet color cartridge only to find out that even my online bank statement has one small little blotch of red and 8 pages of black and white prints in very basic font.

And that’s not even the hard part. Practically laughing at me, the clerk at Bank of America had to get the manager when I read this condition for the application:

The latest 3 months bank statements which are e-statements must be supported by an original letter from the bank verifying the validity of the accounts and addressed to:
To Whom it may concern

After several appointments, the bank informed me only a centralized banking center in Tampa can give verification of client information and of course, the branch is unable to receive the letter by fax or email so I’d have to go home, call from my home phone and have it sent to my email. Unwilling to give anything but the last 4 digits of a an account, I learned that in a post 9/11 world a bank can barely even verify your assets in writing thanks to strict anti-terrorism rules that serve the interests of policy makers trying to show America how they’ve secured the homeland against all foreign threats. The image below shows how the U.S. government’s banking privacy rules “protect us all from harm”.

us regulations

Eventually I explained all this to Joy-Stay and finally got them to accept a the very scantily written form letter from the centralized banking center stating my full name and confirming I did have a checking account as of a certain date identified as XXX-XXXXXX-1234. Requiring this documentation with the application, you would assume it sufficiently satisfies the ministry’s guidelines. Unfortunately, there is yet another step. Along with the above referenced information, item # 14 asks for:

Bank Authorization Letter to authorize the officers at MM2H centre to verify your accounts with your financial institution.

Printing out the form our agent sent me, it occurred to me that this letter is basically “verification of the verification”. Already possessing a letter from the financial institution that confirms an applicant’s bank statements are legitimate, the ministry supposedly uses the “bank authorization letter” after receiving an applicant’s paperwork. Sent by snail mail, the ministry expects your financial institution to open and read a letter sent from a foreign government blindly asking for vital information on a client’s bank account number and assets. Roughly akin to a spam email like when a Kenyan tells you you’ve inherited money and you should click here, I’m wondering what country still has a banking system that would take that seriously.

The MM2H bank authorization letter

The MM2H bank authorization letter

Most Americans know how any bank employee would react to the “bank authorization letter” (Hint: Unless a bank employee wants to join me on the unemployment line, the letter hits the shredder or perhaps gets passed to a supervisor so they can trash it.) Fortunately, the “bank authorization letter” has generally been overlooked for American applicants because they’re aware of stringent US banking rules. Effective November 1st, 2014, however, someone decided to stop ignoring it, so they’ve started “selecting” certain American applications for enforcement of this very redundant piece of documentation.

Voicing my concern, our agent responded by saying that the rule is brand new and one of her American clients that recently filed their application has been “selected” for more verification but she has no idea what the results will be. Four weeks later, I’m told there is still no decision or word on how the ministry will handle it and they’ve even tried asking the Malaysian Embassy in the USA for help as if they can somehow change US privacy policies as they apply to banks.

myrI forgot to mention the “cash-in-hand” rule that requires an applicant to show liquid assets of RM 350,000 (about $105,000 USD). Separate from the income requirement I’ve discussed above, the rules are the same except they will consider investment assets along with CD’s, cash or other liquid assets. Financial advisers generally tell clients to keep no less than 5% but no more than 10% of assets liquid. Doing the math, this means an applicant would need between $1 million and $2 million in assets if they held that amount in “fixed deposits” or CD’s.

broker logosAlthough we’ve increased our net worth in five years through diligent investing, we are not wealthy and don’t have a few million lying around. Therefore, I decided to use our emergency money (in a CD) along with brokerage assets in our retirement accounts to satisfy the “cash-in-hand” requirement which our agent agreed to. U.S. brokerage firms don’t necessarily have to follow the strict banking rules and after some conversations with our online broker’s customer service, I’m confident they have no problem answering the ministry’s request. They even put notes on my account instructing clerks not to treat a letter from the Malaysian government as spam. Kudos to the Wall Street lobbyists for once.

Figuring less paperwork is better now that stricter rules are in place, I sent an email to our agent asking them NOT to use our emergency funds in a fixed deposit as partial consideration for our “cash-in-hand” and instead, consider only our brokerage assets. Surprisingly, her response gave me even more cause for concern:

Recently, some officers at the Ministry have stressed that the MM2H committee prefers to see the actual cash available in normal savings, checking or FD accounts. Therefore, we hope to obtain a more definite answer from the Ministry by showing them the last 3 months of your 3 accounts with XXXXXXX

Feeling like Bill Murray in Groundhog Day, I responded by once again explaining that fixed deposit interest rates are near zero in the USA and no sane investor would keep over $100,000 USD in a checking account or a CD that earns pennies every year. Even wealthy investors would probably have minimal amounts in US-based fixed deposits. Responding with an unanswerable question, our agent inquired what I think the value of our investments will be over the three-month period before our application filing.  (January through March 2015).

financial shitIf I knew the answer to that question I’d be a prophet. Explaining again that our assets are mostly mutual funds where the values fluctuate depending on market conditions, I reassured our agent that even a catastrophic market collapse like 2008 would still leave us with enough to satisfy the ministry’s “cash-in-hand” requirement but I suspect she’s feeling very uncomfortable about changes that threaten her livelihood. Although nobody has yet been rejected based on this strict enforcement, it’s starting to sound politically motivated to me and as potential expats, its best to steer very clear of any political opinions or viewpoints.

Making the situation a bit worse, the ambiguous notice from Bank of America implies that by next summer our only “banking center” will be in San Francisco, 24 miles west and a $12 commuter train ride away. Asking my local Bank of America branch to allow their address on the “bank authorization letter” was hard enough and since we can’t file until April, I’m not even sure if the same manager will still work there. Calls to Bank of America inquiring about the notice led nowhere and naturally, nobody in the Too Big to Fail Bank can give any additional information about the notice.

Ambiguous notice from my bank

Ambiguous notice from my bank

Feeling like I’m caught in a system that no longer wants us, I’ve written another extensive letter to our agent providing some recent statements and asking for more clarity. Unlike earlier emails, I’m beginning to stress that we’d be really unhappy shelling out $1,500 in fees if they can’t guarantee approval with the same certainty they did when I started the process. Once we close escrow, we’ll have 30 days until we’re homeless and rentals here in The Bay Area are too expensive even if there were any available. Knowing we can’t stay at Diane’s relatives very long without becoming a burden, I’m a bit unsure what to do at this point.

 H E L P !!

H E L P !!

Thanks to several generous folks we met through this blog who agreed to meet, provided their email addresses and even gave us the names of similar agents for procuring Thai visas, we feel confident we’d have some guidance if we choose Thailand. Because the timing becomes tricky and we’ll no longer have employment income, I’m a bit concerned about flying to Malaysia while the visa status remains unresolved given the stricter rules but don’t think we’ll be able to wait it out in North America. Barring a situation where we can’t sell the house, we’ll need to flee like refugees.

Summarizing, American citizens thinking of applying for an MM2H visa for retirement in Malaysia may want to sit tight, consider another option or somehow make friends with a high-ranking government official that sits on a Banking Committee and can manipulate the system in your favor. Meanwhile, we are off to Canada soon for a cold Christmas with Diane’s family when I will be too busy eating ketchup potato chips, Coffee Crisp bars and KD (Canadian mac & cheese) to care about the dilemma.

The Experimental Expats want your opinion: Please comment and help us out:
Should we leave for Malaysia after we close escrow even if the status of a visa approval is not certain or should we go to Thailand instead ?

Coming this weekend: The Galapagos Islands Cruise : Day 3
If you missed any, Day one is here
 and Day two is here

14 thoughts on “MM2H Update: Reconsidering Thailand; Visa issues intensify

  1. pproctor10 (Paul & Bonnie)

    Also, as another input, our Agent advised getting actual business cards from the branch manager at Wells Fargo and Schwab and send those in as well (which we did), also for every position that I documented on my “resume” I also supplied old business cards which corresponded to each job ( thankfully I always kept a few) I think this might have given some additional credibility to the application as it would have been a lot of work to manufacture those business cards and also the PDF files from the bank and brokerage were in full color and 10 – 30 pages long each. as for getting certified true copies of documents, I found a Document Custodian Certification form and self certified everything myself with the help of a notary and they accepted it. I was able to get certified copies of our marriage license from the state, but nobody would certify a drivers license or passport etc.. So I used that form I found and they accepted everything. If anybody would like a copy of that form, let me know

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    1. rodi (Rob and Diane) Post author
        Sounds like you did as much research as me and cut a few corners. I didn’t want to take any chances so I used Joy Stay. Yvonne guided us through every step and she has contacts at the ministry that ensure what we send will be acceptable even before she files the application. They have never had an application rejected by Americans except one exceptional case that involved child support as the income so hopefully all will be well. Thanks for sharing all your information

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  2. pproctor10 (Paul & Bonnie)

    We just picked up our MM2H visa’s in April 2015. Our approval happened in June 2014 but we had to get an extension for the final trip. We used Alter Domus in Penang as our MM2H agent and had no issues. We only submitted the emailed files of PDF bank statements from Wells Fargo and Charles Schwab and those were accepted without any issues. We filled out all of the verification forms, but I do not think they actually used them, no way to know this though

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    1. rodi (Rob and Diane) Post author

      Alter Domus was my original choice but we thought the Chinese guy who initially corresponded with us was way too pushy and their fee was more than Joy Stay. We also hope there will be no verification request but all we can do is wait and see. Now that escrow closed we are not really in a hurry

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  3. Lawrence

    Dont be discouraged! The waiting could be unnerving, and I bet those MM2H visa department staffs are in a holiday mood and in no hurry to do much. Have plan B for Thailand but for now, stay focus on plan A. The 90 day visa could be renewed easily just by going to Singapore and return the next day. I dont think they will give you any problem at all. I would just tell them that you are waiting for the MM2H approval process. Meanwhile, you could prepare plan B for Thailand if Malaysia’s MM2H doesnt work out. If I were you, I would use a small Asian bank such as Cathay or East West bank in California and go to the branch where you get to know the branch manager. They will be more willing to write a letter for you and you could put the name of the manager at the branch as verification officer with contact info. I m sure that it will work out. Due to time difference, I doubt that they(MM2H) will call. The most they would do is email. When we apply for our MM2H, they requested the authorization to verify from our bank too. We gave them our local branch officer’s contact info but no one ever verifies with him. Employees of bank of America probably havent heard of such letter or have the slightest idea. Thus this could be frustrating. Some of the notarization could be done by the Malaysian Consular office for a fee. They probably have the “Certified True Copies” stamp with them. Just my two cents of feedback. Wherever you choose, all the best. Focus on plan A but always have a plan B. Sometimes no news is good news. Dont be over stressed by the inefficiencies of the powers to be. Both of you could be happy either Malaysia or Thailand. Cheers!

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    1. rodi (Rob and Diane) Post author

      Thanks for the comments. We have not applied yet and are already in the three month income period so we are not changing banks now. The cash in Hand is coming from brokerage accounts which are not subject to such strict rules like the banks.

      This means the only thing that needs to be “verified” would be our three months of bank statements and I’m not going to worry about it. Hopefully they don’t ask for verification but if they do too bad. You are correct. Bank of America will never know what the MM2h is and will never write any kind of letter.

      If all else fails Thailand is a fine place for us. We love Chaing Mai anyway

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  4. rmgthatsme

    I believe you credit the people who make these decisions with far more of a “world awareness” than they are likely to have in reality. The MM2H programme was designed to attract high net worth applicants to Malaysia. The fact that these same people would have far wider and more attractive options than Malaysia seems to escape them. The programme is attracting many wealthy Chinese and Japanese who do not have the banking barriers Americans have created for themselves. if you expect the Malaysians to adapt their requirements for US applicants I’m afraid you’re in for a disappointment. The US government’s control over its citizens’ money is so overbearing that many banks in Hong Kong where I’m currently based will not even open accounts for US citizens. Why not consider Thailand with a retirement OA visa. Gives you a year there which is renewable and has less financial requirements for cash deposits and you can use the cash for you living expenses while there as well. You still have to do the 90 day reporting to the authorities but if this is too onerous for you, you can also get a local agent to do it for you while you work on your tan. I’ve given up on Malaysia more from a security viewpoint and the increasing Islamic bloc appeasement policy of the government. Yep, Thailand here come. Do some research on Thaivisa.com and you’ll get all the pros and cons you need. Hope this helps.

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    1. rodi (Rob and Diane) Post author

      Hi
      Thanks for the input; you obviously know what’s going on there.

      I actually agree with everything you say. I am a 30+ year employee of the financial services industry and my in my last job the bank was the parent company so I know all about compliance rules. I also know all about the government’s tight noose on its citizens and could start an entire blog on what absolute bullshit it all is but I promised Diane I’d keep only positive comments and attitude on this blog.

      From what we understand, everyone who goes to Thailand loves it so I have no problem going there as an alternative and yes, I’s just use an agent to take care of retirement visa renewals once we obtain a 90 day or 1 year visa so at this point we’re going to sit tight and see what happens. We are not high net worth but do have more than double the financial requirements for MM2H in total asset. But we intend to live only on house proceeds for 15 years and Thailand would be cheaper anyway.

      Then there’s the plummeting MYR that is causing me a bit of concern at the moment so there are many issues to think about. Either way we’re going somewhere because nobody is lining up to hire a 50 year old operations peon that worked for double what they hire kids for today. The blog is a great resource for us to get ideas and input so thanks for your honesty

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    1. rodi (Rob and Diane) Post author

      We might consider flying to Malaysia and entering on 90 day tourist visas although we’ve heard if you leave and re-enter much more than one or two times, they’ll flag you as trying to enter and work illegally and would probably certainly reject the MM2H. Honestly, if they can’t resolve and approve after 90 days in the country plus the extra month or two they will have already had, we’d probably give up and go to Thailand.

      The only stumbling block appears to be political. They know the Bank Secrecy Acts do not allow a bank to blindly disclose client information in writing even if the client says they are asking for it. I’m not sure if they understand that there’s no such thing as a “bank officer” contact in the USA anymore (maybe in the midwest but certainly not here in California)

      They also seem unwilling to understand that everything regarding verification goes through a centralized banking center with no names and contacts if you use any half way large sized bank. That’s why I suspect this may be a political issue designed to make the program unworkable for American citizens because it’s obviously unfair to ask an applicant to provide documentation prohibited by statute.

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    1. rodi (Rob and Diane) Post author

      I just heard back. The story remains the same: Brokerage assets should be no problem as “cash on hand” but if the financial institution will not reply in a timely manner regarding the “bank verification letter” it will either delay or eventually be rejected.

      Bottom line: If they choose to “select” and try to contact any bank directly, every American will be rejected because no bank in America is ever going to send a reply to a foreign government asking for client information; it violates the bank secrecy act.

      Rock and a hard place. We will cross our fingers that ours is not “selected” but if it is, Thailand will be fine for us

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