Legitimate Customers with No SSN
01/07/2002
How do we deal with people who want to open accounts and have no social security numbers - such as the Amish people - especially if we have to file a CTR?
Barbara Hurst is Executive Editor of the BANKERS' HOTLINE, a highly regarded newsletter written for financial institutions, she is President of Hurst Associates, Inc., a Pennsylvania based corporation that specializes in security and compliance training programs, and Editor/Moderator for BankersOnline.com.
Ms. Hurst spent over fifteen years in the banking industry, as officer in charge of investigations and claims at a large Philadelphia, PA bank (...since purchased by PNC Corp.) She served as chairperson of the Security Committee of the Pennsylvania Bankers Association, and is past president of the Bank Methods Association. During her banking career, she won the coveted National Public Speaking Award in 1977 from the American Institute of Banking.
Since starting her own corporation fourteen years ago, Ms. Hurst has presented workshops, speeches, programs and training sessions for over 400,000 bankers in 42 states in the U.S., in San Juan, in London, and in Moscow.
Barbara's workshops for security, regulations, and compliance are regularly on the agendas of financial associations and institutions, at conferences, and for security officer's groups and training schools. She also does programs for regulators, law enforcement, corporations and the U.S. government on the subject of bank fraud and security.
Barbara has been listed in five "Who's Who" publications, including Who's Who of U.S. Executives, Who's Who in Business and Finance, and Who's Who in U.S. Commercial and Savings Banking. She is a member of ASIS, and is affiliated with National Fraud Center, Inc.
She is the author of an award winning EXAMINATION HANDBOOK FOR SECURITY OFFICERS, and was a core faculty member on a TV training channel for the American Bankers Association. Barbara has also just completed a series of front line training videos for the Bankers Video Library covering the subjects of Robbery, Safe Deposit Service, Fraudulent Checks, New Accounts, BSA and Reg. CC.
01/07/2002
How do we deal with people who want to open accounts and have no social security numbers - such as the Amish people - especially if we have to file a CTR?
01/07/2002
We have an account for an 18 year old (his name individually - Chuck Doe). He brings in a check drawn on another FI, payable to John Doe custodian, Chuck Doe UTMA. It is endorsed by John Doe (although not in our presence) and presented by Chuck for deposit to his personal account. How should we handle this? Clearly there are issues with whether it is actually John's signature but what else on the UTMA side?
01/07/2002
How do you calculate the last digit in a routing number - using the fraction in the top right corner of the check?
01/07/2002
Does a late return apply to checks on first presentment or can they claim late the second time it is being presented?
01/07/2002
Who is the expert on processing ATM deposits? A local TV station has referred me to gov't agencies regulating banks. I have explored Reg. E on my computer and no reference is made to processing ATM deposits.
01/07/2002
We are facing a potential loss because of a bookkeeper stealing checks from their employer and forging our customer's signature. Our customer's attorney alleges that we were at fault for not spotting the signature variations on checks over $2,500 (the bank's policy) that were reviewed by us. The alleged fraud dates back to March 2000. My question is: Is there a standard threshold amount that most banks use when reviewing incoming/inclearing on-us checks? Is $2500 a reasonable threshold? What process is used to determine that a signature is irregular? Is the customer contacted? Does the branch get involved?
01/07/2002
If you have a check payable to 2 people, can the item be deposited into an account where payees are joint with only one endorsment?
01/07/2002
I have a question regarding the GLB privacy provisions. Our tellers place customer account numbers in their teller machines as reference to the transaction being performed. If a customer presents a check not drawn from their own account, their account number is placed on the back under their indorsement. By requesting this account number, would this be a violation of the GLB privacy provisions? My thought is that the bank would then be providing non-public customer information to a third party, which is against ourprivacy policy.
01/07/2002
We have been requested by our Commercial Loan area to help out an existing customer. The existing customer is being taken over by another Company and the existing customer would like to keep the existing account number but change the name and the reporting 06 TIN number on this existing account. My question is there any requirement by IRS or any others that we close this account and open another? We have always closed these accounts in the past but I think this was more a Bank requirement then a legal one. Am I correct in this?
01/07/2002
In the following situation, who is liable? A corporate customer found unauthorized checks in their statement. The checks were "signed" with a signature stamp and stolen, but the company did not know this. All of the checks were cashed at the bank following appropriate procedures to check identity.