09/12/2011
During our annual internal audit of Reg. O, we discovered that overdraft fees are being waived for the board of directors. The overdrafts were under $1,000 and the account was not consecutively overdrawn for 5 days or more. At first, we felt that we could defend this by proving that our BOD is in similar circumstances as other depositors that we waive overdraft fees for. Management has decided that proving these "similar circumstances" may not be a risk we want to take with examiners. How should we handle this violation? Should we have the board members that are in violation pay the fees that were waived? Or should we implement training and awareness to ensure this violation does not happen again?
08/29/2011
A director (reg o) has a loan. Can the due date be extended each year without board approval with the same interest rate? This loan started in 2007 and each year the due date has been changed for another year. The loan is an unsecured loan for 25,000. Also, this director has another unsecured loan for 5,000 with the same thing happening.
08/15/2011
I have a customer who is the sole member of a corporation. He has been told by his attorney and accountant that he can cash a check made payable to the corporation. This is not our bank's practice. Can you direct me to something printable to give to my customer stating guidelines for cashing business checks?
04/25/2011
What are the responsibilities for an In-House Auditor? Our auditor considers daily activity of the employees as an auditor responsibility.
04/18/2011
Do we have to have job specific training for BSA?
03/07/2011
What is a Compliance Management Program?
02/22/2010
How often should the Board of Directors be trained by the Compliance/CRA officer on CRA policy?
06/08/2009
Reg O Section 215.10 reads: Each executive officer or director of a member bank the shares of which are not publicly traded shall report annually to the board of directors of the member bank the outstanding amount of any credit that was extended to the executive officer or director and that is secured by shares of the member bank. Question: Must the insider's name be on the report, or is it sufficient to report "one insider has X amount secured by shares of the member bank"?
04/20/2009
Does BSA/AML risk assessment have to be approved by the board?
03/16/2009
A big part of our IT Security budget is spent on GLBA compliance. Are we doing something wrong?