07/01/2002
Our organizational structure consists of a single bank charter that is whollyowned by a bank holding company. Can we meet the requirements for SAR reporting to the Board of Directors through a holding company Board Committee, or must the reporting occur to the Board/Committee of the subsidiary bank itself?
05/06/2002
I know I have to let the Board of Directors know when a SAR is filed. I was told all I can tell them is that one is being filed. Is this correct... how does it get in the minutes and what does it have to state?
04/01/2002
We need to replace a BSA officer for one of our subsidiary banks. Does the new replacement need to be an "officer" of the bank? We have an employee of the bank that is knowledgeable of this area, but they are not classified as a bank officer.
04/01/2002
Are banks required to have independent auditing of their Bank Secrecy Policy and files? If so, what should the audit consist of?
04/01/2002
I recently read your response <a href="http://www.bankersonline.com/articles/v06n03/v06n03a17.html">Reporting SARs to the Board of Directory</a>. Is there some legal authority which I can show our Boarch of Director's secretary? Our Board has, in the past, seen SARs and decided on whether or not to file before they were sent in. What is your take on this? As compliance officer, I think they should not be informed until after the SAR has been submitted.
03/04/2002
In Section <a href="http://www.bankersonline.com/regs/215/2155.html">215.5 (c) 13</a>, the regulation is a little confusing and I was hoping that someone may have questioned this before. This involves loans from member banks to our executive officers. It mainly starts with <a href="http://www.bankersonline.com/regs/215/2159.html">12 CFR 215.9</a>. It then references section <a href="http://www.bankersonline.com/regs/215/2155.html">12 CFR 215.5(c) 13</a>.My question is if the extension of credit is:(1) In any amount to finance the education of the executive officer's children;(2) In any amount to finance or refinance the purchase, construction, maintenance, or improvement of a residence of the executive officer provided it is secured by a first lien and the executive owns the residence.Is the executive officer required to disclose this information to the board of directors within 10 days as required for any other credit over $100,000?I have read this section over and I am not clear on whether the executive is to report or not report.
11/05/2001
I am looking for a list of the most current bank policies that must be approved by the Board of Trustees.
04/01/2001
The revised rules and regulations required by the Bank Protection Act have placed a greater responsibility on financial institutions, their boards of directors and their security officers/managers.
04/01/2001
It is one of your toughest responsibilities. You have ten minutes or less to tell the board of directors about a compliance problem or a compliance program need.
01/15/2001
The federal banking regulators have agreed to on final Interagency Guidelines Establishing Standards for Safeguarding Customer Information ("Guidelines"). You previously wrote two articles for us on the proposed guidelines. (See <a href="gurus_technology1211.html">Part 1</a> and <a href="gurus_technology1218.html">Part 2</a>.) Were there any surprises for you in the final version of Interagency Guidelines Establishing Standards for Safeguarding Customer Information? And could you give us a quick heads-up on what the final guidelines provide?