07/15/2002
Are we allowed to photocopy treasury checks?
07/01/2002
Under OFAC regulations, if a noncustomer wishes to purchase traveler's cheques and we get a match with the OFAC list, do we retain the funds and put them in a blocked account or do we refuse the transaction?
07/01/2002
We are having a difficult time getting some of our "better" commercial customers to close their accounts when fraud/forgery/etc has occurred. Any advice on content or where to go for an indemnification agreement?
07/01/2002
This is a strange situation. We have a business account that we can not find resolutions for. From looking at the signature cards, it would appear that person A opened the account and added person B four months later. At some point in this business relationship, it went sour between person A and Person B. Person B came in and requested we remove person A from the account. We told person B that we had no authorization to remove person A based on person B's request alone. (got this?) We told both of them that they needed to resolve the situation and one possiblilty was to close the account reopen another with the sole person on it. What happened, however, was Person A withdrew funds while Person B wrote checks causing the account to go into overdraft. NOW person A wants to be removed. We say no, not until the account is brought back to zero. Please explain what procedures and/or regulations pertain to removal of names from a business account!
07/01/2002
I have a situation where a person's care has been turned over to the county. He currently resides in an assisted living facility. He is mentally disabled and cannot sign his own name. His parents would like him to open a checking account to pay for daily items, bills, food, etc. The question is: 1) May the county, although not legal guardian, allow his assisted living home sign for his purchases and manage his account (since the home will be the ones with him when he makes his purchases), and 2) what is the best way to choose the signers for his account to verify that the funds in his account are "safe"? (preventing exemployees, or current ones for that matter, from taking advantage of their position of signing for him.)
07/01/2002
<a href="http://www.bankersonline.com/compliance/gurus_cmp060302d.html"> Regarding answers by John Burnett and Ken Golliher</a> on holds on credit card checks and insurance drafts, if our policy (Reg CC) provides for casebycase holds and we don't need a reason to place, then we would be free to place a 2 or 5 day hold on these items? Is this a reasonable understanding?
06/17/2002
Our lenders usually issue a proceeds check at the same time the customer is in their office to apply for a loan. Their question to me was, if a customer is sitting there waiting for their check, the lender checks the OFAC listing and the customer's name is a true hit what do they do from there? How do they handle the situation?
06/17/2002
Can an attorneyinfact use the POA to open a new account for the principal? Especially a new account naming the attorneyinfact as a secondary or joint account holder?
06/17/2002
The regulators have said that verifying funds availability on a check is okay under an exception to the privacy rule. What about verifying if the check has been paid? Would that also be considered okay as part of verifying funds availability to a merchant?
06/03/2002
We would like to know why we cannot put an exception hold on a credit card check or a insurance draft. A credit card check is truly a request for credit and an insurance draft is not a check. These checks have restrictive endorsements. We just participated in a Pegasus phone seminar and the gentleman replied that the Reg states that we cannot put a classification on a specific type of check.