Most Popular Compliance Content
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.
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?
Family Trust-Individuals Use Separate SSANs?
04/14/2019
John and Cindy both have individual accounts and just created a family trust which has no tax number. Can they use their separate SSANs for the account without adding the other person as joint owner?