Most Popular Compliance Content
Consumer Protection for mistake in loan payment transaction
08/25/2024
Scenario: A bank employee inadvertently makes an error while processing a payment authorized by phone by the customer, for example, customer authorized his/her personal loan monthly payment of $100 but the employee processes a debit for $101, or $96. Could this be considered an unauthorized electronic fund based on the amount error? Can this be considered a violation of other consumer protection law/reg? UDAAP?
Lost Debit Card
08/25/2024
We have a customer that lost their debit card but didn't notify us until day five. Under Visa's zero liability policy, would this be considered "gross negligence"? The charges do not all add up to $500.00, so are we required to give the customer any credit at all?
Records retention and canceled remittance transfer
08/18/2024
Regarding a cancellation request of a consumer foreign remittance transfer - are there any document retention requirements related to the canceled wire transfer request? Is the FI required to retain a copy of the wire transfer request form or any other documentation related to the transaction since it never occurred if canceled within the 30-minute window? Our bank has a log to record all canceled international wire transfer requests, but that is the only documentation.
Completing CTRs on a business account
08/18/2024
When filing a CTR on a business deposit, do you include everyone on the account like you would a personal CTR or just the actual conductor?
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?