Most Popular Compliance Content
Adding to Time Acct. After Initial Funding
04/28/2019
Can we put a cap on how much may be added to a time account after the initial funding? For example, if a customer opens a time deposit with $5,000 and then wants to add $100,000, we would not allow that. Can we put a restriction in place that you could not add more to the account during the term than the original amount, so if the account was opened with $5,000 that they could not add more than an additional $5,000? Also can we allow an HSA CD to be a time account, or are there restrictions on this?
How Long to Retain "Referral Authorization"
04/21/2019
Any idea how long we need to retain a "referral authorization" that we have between a collection agency and our customer?
Exempt Non-Listed Business: Savings Acct. CTR
04/21/2019
Are savings account transactions considered exempt from CTR reporting for the business customer that is an exempt non-listed business? What about cash payments to a loan account? From 31 CFR 1020.315: The exemptible accounts of a non-listed business or payroll customer include transaction accounts and money market deposit accounts. From Federal Reserve Act 19(b)(1)(C): The term "transaction account" means a deposit or account on which the depositor or account holder is permitted to make withdrawals by negotiable or transferable instrument, payment orders of withdrawals, telephone transfers, or other similar items for the purpose of making payments or transfers to third persons or others. Such term includes demand deposits, negotiable order of withdrawal accounts, savings deposits subject to automatic transfers and share draft accounts.
Easier Way to Sign Up for E-Statements: In-person
04/21/2019
We would like to create an easier way for our consumers to sign up for E-Statements. What are the requirements, compliance wise for this? Currently, our customers need to log into their online banking, view a PDF disclosure that generates a "code", and customer then has to type in code and agree to terms and conditions. Compliance wise- can consumers just sign the disclosure/consent in person at lobby?
Master Repurchase Agreement Sample/Copy
04/21/2019
I would like a sample of a Master Repurchase Agreement. Can you help me in finding a copy of such?