Most Popular Compliance Content
Conductor Information for Aggregate CTRs
01/28/2024
We have a business customer whose deposit runners are refusing to provide their information for us to collect as conductors of cash transactions. These are typically smaller transactions, but we require a conductors information on all cash transactions over $1,000 for aggregation reporting purposes. They previously banked at a larger regional bank which did not require these runners to provide identifying information. Are we OK to make an exception for this business client unless it is a CTR reportable transaction?
Using a EIN on a personal account
01/28/2024
We have a customer that is an agent for one of the local insurance companies. She wants to open an account in her name only using the insurance company EIN, can we do that?
Cash Transaction More Than 10K For a Joint Account
01/21/2024
I have a CTR question I have yet to see posted anywhere. Any cash transaction(s) more than 10K to a joint account by any conductor is a CTR. However, what if there are multiple (3) joint accounts. EX: $5,000 cash deposit by Suzy to account A; $5,000 cash deposit by Suzy to account B; $1,000 cash deposit by John Doe to account C. All 3 accounts are jointly held by the conductors. Would this be considered a CTR because Suzy and John can benefit from the $11K, via separate accounts or exempt because not more than one person conducted to a single (one) joint account?
Incentive Progarms and Trust Account Investments
01/21/2024
We recently inquired if we could use self-deposit investments where the bank is acting as Trustee. We have received a legal opinion stating that we can use self-deposit investments so long as we document our due diligence, the trust allows for the investment, and our Money Market Account (MMA) is a competitive rate. We are currently discussing a referral incentive program which would include our Trust Division. I have read a lot of guidance between FDIC, OCC, and FRB, but I am not seeing anything that speaks to my particular situation. Can a Trust Officer use a self-deposit investment as Trustee and still receive a referral incentive for this transaction? I personally feel like this is a conflict of interest and somewhat, self-dealing. However, I am not seeing anything stating this would be an issue per se. I am only running into nonretail deposit and broker/dealer requirements. I have also looked through Arkansas code (our state) and I could not see anything that spoke on this particular situation. If you have any insight or could point me in the right direction to help confirm or rebuttal my though process, I would really appreciate it!
How should a check "for" another read?
01/14/2024
Is a check payable "FOR" someone the same as a Representatives Payee? I've seen checks that do not have "Representative Payee for..." just "For..." John Doe FOR Sally Doe Is this sufficient, or what should it read?