Most Popular Compliance Content
Opt Out Early Deposit
02/13/2022
Our bank offers early access to direct deposit funds, up to two days early depending on the timing of the submission from the payer. The bank wants to add an Opt-Out option for customers who prefer not to receive direct deposits early. Could you please confirm there is not a operational or regulation reason why the bank cannot accept an Opt-Out request either verbally or in an email. We want to make the Opt-Out option easy for the customer without requiring a signed form. The bank plans to document the customers name and date of request in an account note.
Incentive payments and 1099s
02/13/2022
Our bank would like to give current customers $25 cash to refer a friend. We have been advised that those clients must then receive a 1099 at year end for the "gift." I've seen other banks do this successfully so are they all issuing a 1099?
MSB Registration
02/13/2022
Does a Money Service Business (MSB) who is registered through the state Nationwide Multistate Licensing System (NMLS) still have to register as a MSB separately with FINCEN?
So are we responsible ?
02/06/2022
We sent a check out in our cash letter, and the check number was encoded wrong. That is it, nothing else. When the makers bank received the check, they paid it. Then days later they realized that check had a stop on it. The stop was on ck# 1855. We sent the check to that bank with no check number at all. Our machines did not pick it up. They are wanting us to pay them back for the check because we sent it out without the check number, however they missed the stop too. The check suspected and they failed to notice the check number was not correct and it had a stop on it.
So are we responsible ?
02/06/2022
We sent a check out in our cash letter, and the check number was encoded wrong. That is it, nothing else. When the makers bank received the check, they paid it. Then days later they realized that check had a stop on it. The stop was on ck# 1855. We sent the check to that bank with no check number at all. Our machines did not pick it up. They are wanting us to pay them back for the check because we sent it out without the check number, however they missed the stop too. The check suspected and they failed to notice the check number was not correct and it had a stop on it.