Most Popular Compliance Content
Adding PODs on Joint Accounts
01/28/2024
When a customer has joint account and only one person on the account wants to add a beneficiary to the account, can this be done or must each accountholder agree?
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?
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!
Carte blanche to an Authorized Signer
01/21/2024
What are your thoughts on allowing customers to give an authorized signer access to their online banking and/or approving them to have a debit card? Would it make a difference if there is a form signed by the customer providing authroization and acceptance of liability for the transactions the signer conducts?