09/22/2008
What position (head teller, loan officer, etc.) of the bank would be the best candidate for our BSA officer? Would it be our compliance officer?
08/18/2008
03/31/2008
I plan to include a recommendation in my annual report to change the current reporting structure for the Security Officer. Presently, I report to the VP of Retail Operations. I am seeking references to cite that advise the bank security reporting structure should be in other areas such a finance, risk, administration, but not through retail because of the apparent potential for downward influences and the need for independence.
12/10/2007
How in-depth should the training be for the Board of Directors in BSA? Is a general overview of BSA/AML/CIP along with an overview of the procedures in place sufficient for compliance?
11/26/2007
Please clarify if the following transaction would be considered a refinance or a purchase. We have a newly elected Director on our board. His home loan was approved before he became a director. After he was appointed to the board, his home loan was modified. Should this have come before the board to obtain approval?
10/15/2007
The chairman of our Board of Directors is buying a house. Can we waive the 1% origination fee without being in violation of Reg O? We do on occasion waive this fee for other customers in order to compete for a loan.
09/03/2007
I've been told that when 100% of a bank stock is issued by a holding company and it is not publicly traded, the reporting requirements under section 215.10 of Reg O do not apply should an executive officer or director pledge the bancshares as collateral for a loan at another financial institution. I cannot substantiate this claim. Have you ever heard of this?
07/09/2007
We are having a misunderstanding at my financial institution about the USA PATRIOT Act. We were first opening corporate accounts and gathering identification documentation and social security numbers on all the signers on corporate accounts. We were then instructed that it was unnecessary to obtain this information on the signers. Then about a year later we were instructed that the USA PATRIOT Act does require us to get this information. Does BSA or the PATRIOT Act require financial institutions to get ID for signers on corporate accounts as of 2007? If it does not, where can I find this information?
05/21/2007
I have been newly appointed to a bank Board of Directors and have little banking knowledge. I have been approached by one of our tellers with a concern about CTRs. It seems that on a regular basis (couple times a month) a customer comes into the bank with two checks around $6500.00 each and has them cashed. One is in his name the other is in his father’s name. Each time he is alone and walks out of the bank with around $13,500.00 cash. My teller is afraid that this is a BSA violation. Is this a violation? Would this at least warrant a Suspicious Activity Report?
10/09/2006
What are the bank policies that need board approval and how frequently?