Most Popular Compliance Content
Adding PODs on Joint Accounts
01/28/2024
When a customer has joint account and only one person on the account wants to add a beneficiary to the account, can this be done or must each accountholder agree?
Conductor Information for Aggregate CTRs
01/28/2024
We have a business customer whose deposit runners are refusing to provide their information for us to collect as conductors of cash transactions. These are typically smaller transactions, but we require a conductors information on all cash transactions over $1,000 for aggregation reporting purposes. They previously banked at a larger regional bank which did not require these runners to provide identifying information. Are we OK to make an exception for this business client unless it is a CTR reportable transaction?
Using a EIN on a personal account
01/28/2024
We have a customer that is an agent for one of the local insurance companies. She wants to open an account in her name only using the insurance company EIN, can we do that?
Carte blanche to an Authorized Signer
01/21/2024
What are your thoughts on allowing customers to give an authorized signer access to their online banking and/or approving them to have a debit card? Would it make a difference if there is a form signed by the customer providing authroization and acceptance of liability for the transactions the signer conducts?
Cash Transaction More Than 10K For a Joint Account
01/21/2024
I have a CTR question I have yet to see posted anywhere. Any cash transaction(s) more than 10K to a joint account by any conductor is a CTR. However, what if there are multiple (3) joint accounts. EX: $5,000 cash deposit by Suzy to account A; $5,000 cash deposit by Suzy to account B; $1,000 cash deposit by John Doe to account C. All 3 accounts are jointly held by the conductors. Would this be considered a CTR because Suzy and John can benefit from the $11K, via separate accounts or exempt because not more than one person conducted to a single (one) joint account?