Skip to content
 

Latest Compliance - Compliance/Compliance Management Topics

Subpoena/summons investigations results and SAR filing

08/11/2024

Our BSA Officer manages our bank’s filing of Suspicious Activity Reports (SARs) with FinCEN. She has asked to include in our policy for managing summonses, subpoenas and similar legal documents a requirement that she be notified of any suspect activity that might be turned up in searches in response to those documents. Is that allowed?

Identifying "protected funds" in a joint account

07/28/2024

When we receive a garnishment order identifying a judgment debtor who has a joint account at our credit union, and there are federal benefits that have been direct deposited for both of the joint owners of the account, which of those direct deposits do we treat as “protected funds”?

Is a wheel-spin game allowed?

07/07/2024

We have a “spin the wheel” promotion. To spin, a customer must donate $1 that the bank donates to a charity. All the prize amounts on the wheel are more than $1 therefore all customers will get more than they donate. The amount won is then sent to the customer via our e-wallet app. We set a certain number of spins and it is done on a first-come-first-served basis.

Internal raffles matter

06/23/2024

Can we do an internal raffle (selling tickets for a chance to win a prize) to benefit a non-profit organization?

Lottery Exceptions

06/16/2024

Now that banks can participate in lotteries, can we facilitate raffles unrelated to the bank for local service groups, posting lobby posters or selling tickets for or be a sponsor, etc.?

Pages

Most Popular Compliance Content

Rep Payee and Reclamations

11/03/2024

If Representative Payee dies, what happens to existing funds in the account post reclamation of that months funds? Does the new Rep Payee have authorization to access funds?

Where are Check Return Limits Specified

11/03/2024

Where in the regulations does it spell out the time limits and liabilities for banks regarding counterfeit checks, altered checks, forged endorsements, etc?

Conditioning Overdrafts on Opt-in

11/03/2024

Reg E (12 CFR 1005.17(b)(2)) says we cannot condition the payment of checks and other transaction on the whether the consumer has opted into overdrafts via ATM and one-time debit card transactions. However, it does not clarify whether the opposite is allowed – meaning can you condition ATM and one-time debit card transactions on whether someone has opted into overdrafts via check and other transactions? I can't find any guidance on this question, so any advice is much appreciated.

Next Day - Same Day Availability

10/27/2024

We were recently audited and it was noted that because a customer can immediately withdraw funds from a deposit made that same day, that we should be disclosing as a same day availability bank. instead of next day availability. What is your opinion and how do you recommend wording the change on policy, notices, and disclosures? It seems most examples I find are all next day examples.

Pages

Penalties View All

Search Topics

Compliance Topics