Most Popular Compliance Content
Who to CIP on a Trust
09/03/2023
If we have a revocable living trust, and the Grantor and Trustee are different, would we CIP both the Trustee and Grantor, or just the Trustee?
Debit Card - Cash App Claim
09/03/2023
A customer filed a number of POS transactions originating from Cash App and during our investigation we found out that the charges were linked to a relative of the customer (whom she's previously had issues with). Our customer claims they never authorized this person to use/access the debit card. The documentation stated a physical item was sent to the address that matches that of our customer, but the name linked to the transactions does not match our customer's name. Can we deny this claim since information links back to her address but not her name?
Liability for Stop Payment Error
08/27/2023
We have a customer that placed a stop payment on a check. When the check cleared the check number was keyed incorrectly by the depository bank. Due to that happening the stop payment was not a direct hit, and it appeared on our Suspect List. The person checking off that list saw that the check number was different so they allowed the check to pay from the customer's account. Is our bank liable to pay the customer back for the check or does any liability lie on the depository bank?
Recipient Foreign Tax ID Number
08/27/2023
If a non-resident alien is not legally required to obtain a recipient foreign tax ID number can the phrase "not legally required" be printed in box 13i of Form 1042s, or does the IRS prefer the field be left blank? In our system we have a specific field for the FTIN but for non-resident aliens that report "not legally required" in box 6 of the W-8BEN we enter this information into that field in our system for tracking. When we print 1042s forms the information for box 13i is pulled from this field in our system.
Handling Reg E claims on older transactions
08/20/2023
If an EFT claim is made long after the statement is sent showing the transaction, the rules of investigation don't apply. So why do we investigate any of these claims?