Most Popular Compliance Content
CTR for an ITF Account-Filing Guidance
04/28/2019
We need to do a CTR for an ITF account because the custodian came in and withdrew over $10K. For filing guidance we see examples of deposits, but not of withdrawals. Should the beneficiary of the trust be on the CTR assuming that funds withdrawn were for them? All we know is that the beneficiary walked out with the money. Also, should "ITF" be shown on the CTR anywhere?
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?
Hold on Savings Due to Excessive Overdrafts?
04/21/2019
Can a hold be placed on a savings account due to the customers excessive overdrafts on their checking account? Would this be a Reg CC violation?
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.