Bio:
John Burnett joined Glia Group, Inc., and BankersOnline in 2004, and currently serves as Executive Editor. He is a 1990 honors graduate of the Stonier Graduate School of Banking and is an alumnus of the ABA National Compliance School, where he served on the faculty for several years.
John began his banking career in high school when he started as a teller at a $15 million bank that didn't have account numbers for its checking accounts (he says they actually filed by signature!) He moved to Cape Cod Bank and Trust Company in 1971 and assumed the position of Compliance Officer in 1976. He also served as corporate secretary and secretary of CCBT's Board of Directors, and as clerk of the bank's holding company.
He was a member of the Massachusetts Bankers Association Legal and Regulatory Compliance Committee, and of the American Bankers Association Compliance Executive Committee and NCS/NGCS Advisory Board. He is a regular presenter of BOL Learning Connect webinars and a participant in BOL Conferences events.
Questions Answered
06/04/2023
Are banks required to exempt customers for CTR filing limits? I've worked for banks in the past that never exempted anyone. We just filed CTR's on large cash transactions. So in short is there a regulation stating that banks need to exempt customers, or why is it done?
06/04/2023
Regarding the new small business data reporting requirement expected to come out soon. Will this "1071" requirement be similar to HMDA and CRA whereby if it’s HMDA it cannot be reported as CRA? So if it’s a HMDA reportable loan, then we won't report it for the small business data?
05/28/2023
John Jones makes a cash deposit of $9,600 to the account of his hardware store, Jones Hardware, Inc. He also gives the teller five $100 bills and obtains $500 in $20 bills in exchange. Is there any change to how we will report these transactions?
05/28/2023
A client makes a cash in deposit of $8K. She also does a currency exchange for $5K. We now have a cash in for a total of $13K and a cash out for $5K. Is the $13K reportable since $5k is an even swap? I believe it is but I just need clarification.
05/21/2023
The CTR includes fields in Part I for “gender” (item 7), “contact phone number” (item 18), and “E-mail address” (item 19). They are not identified as “critical” fields. Do we have to ask for this information to complete the CTR?
05/21/2023
Non-real estate loan applicants can use our online form to request a loan. Based on their address we will know if they are in or out of our market area. In some cases an online request is stopped before a credit report is pulled and the person is not allowed to complete the application because they receive a message saying they are outside our market area. The bank does not send any other other notification. Are we required to send an adverse action notice if the bank's practice is to not make these type loans outside of our service area?
05/14/2023
Regarding CIP compliance; do we need to get a updated and current copies of customers IDs after their account has been opened and those ID reach an expiration date?
05/14/2023
Does an online bank (such as Ally Bank or go2bank) have to provide customers with an Image Replacement Document (IRD) when checks deposited via mobile Remote Deposit Capture (mRDC) are returned?
If no, does it then become the responsibility of the payee to work with the maker of the check to recoup the funds?
05/07/2023
Assume we have a single owner account with an attorney-in-fact, the owner dies and the executor wants info on the account transactions prior to death that were initiated by the attorney-in-fact. Can the bank release that info?
04/30/2023
How does a durable power of attorney differ from a power of attorney?
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