08/04/2003
We hold all check deposits in excess of $5,000 two additional days for both local and nonlocal checks. This is our policy and stated in our disclosures. Under Reg CC, do we have to give our customers a notice of extended hold every time a deposit exceeds $5,000?
08/01/2003
Question: We had a customer make two deposits. Both deposits were large checks ($8,000 and $10,500) but the deposits were to different accounts.
08/01/2003
FDIC has issued examination procedures for payday lending.
07/21/2003
After getting bitten a couple of times from credit card checks (or lineofcredit checks) we decided to place 7/11 holds on all checks of this type. Recently, an external compliance auditor informed us that we cannot discriminate against any class of checks so he recommended that we send them for collection. This is causing even longer delays and confusion and it seemed that the 7/11 hold process was much better accepted by the customer. What are your thoughts on this?
07/21/2003
Under Reg D, if the bank makes the decision to close a money market account due to excessive transactions and move funds to another account, does that "other" account have to be interest bearing? The Reg only states that it must be an account the "customer can maintain."
07/14/2003
Student loans are applied for at the college and sent to the state regents for approval. They are then sent to us to fund. We never see the applicant. The name, address, TIN and birth date are fields on the application. Any comments on the verification process? Banks are not permitted to perform credit checks. We do perform OFAC checks.
07/14/2003
Where does Appendix A of Reg CC define a local check? We were previously written up by auditors for treating checks with routing #'s within our Fed District as a nonlocal check. They consider a local check to be only checks processed through the local processing center. Must I complete a new form if the customer’s address changes, or can I note it in my own files and just update my exempt list?
07/14/2003
What are some restrictions and policies to adhere to when beginning the thumbprinting program to reduce fraud? Also, what areas of compliance should be followed? Do we have to post signs at tellers' windows and change disclosure brochures?
07/07/2003
What procedures should be followed in the case of missing travelers checks? We have our internal auditors on the case now. What steps should the compliance officer take and is there anything he/she needs to do or will the security officer have most of the responsibility?
06/30/2003
We have a customer who in the past several days has cashed checks on the same account for $9,500. Our head compliance officer says that a CTR should be completed for the total. I disagree. I think a SAR should be completed because it appears that the customer is structuring and/or attempting to avoid Federal filing of CTR's.