06/21/2004
What law or regulation addresses a bank employee giving out information on banking information to an outside party that has no tie to the account?
06/07/2004
After researching Reg CC, I've concluded that we are only required to provide next day availability on cashier's checks that are drawn on our bank. Is that correct? Can we place holds on cashier's checks drawn on other banks using the case-by-case hold guidelines for local and non-local checks?
05/03/2004
My question is on filling out a CTR. My bank has several business customers who cash checks for their customers. Due to this activity, several times a week they send in an employee with a check (ususally over $10,001) drawn on the business and made out to cash. The employee is the one who walks out with the cash and we assume that the employee is taking that money back to the business. Should we be filling out the CTR section A on the business (making the assumption that the business is benefitting) and put the employee in section B, or fill out the CTR section A on the person who comes in and actually receives the funds even though we think those funds are being used for the business to cash checks? Or even another scenario...filling out section A for both business and employee? Would it make a difference if there was a notation on the check stating "check cashing" or something we might use to know that the funds were going back to the company for use? Wehave debated all ways and wondered what the gurus thought.
05/03/2004
Is is illegal to pay a referral fee to a bank employee for a commercial referral?
04/05/2004
I have just been nominated compliance officer for a Mtg/Correspondent Lender/Mgt Broker in which I am a new employee. I have over 25 years previous banking experience, including some as a HMDA analyst. As a beginner, what courses will best fit me? I am based in Florida. Are there courses offered in my state that cater to a beginner such as myself?
04/05/2004
We are looking at offering a stored value card that will allow our business customers to direct deposit payroll to this card, in a master account, rather than issuing a check or direct depositing to an individual's account. The business issues the card to the employee and they use the card just like a debit card. What disclosures are needed for this product and would these be issued to the business only, since they are our customer, or would it need to be issued to the business and each employee that receives a card?
02/16/2004
We had a situation recently when a customer sent a relative to make a deposit into their checking account. The deposit had a large out of town check in the deposit. The teller neglected to place a hold on that item at the time of deposit; however, I thought we could send the hold out within 24 hours, since the person making the deposit was not on the account. Another employee disagreed, stating that the deposit was made in person, therefore the funds availability hold notice should have been given at the time of deposit. What is your opinion?
12/01/2003
I have just been nominated compliance officer of a thrift at which I am a new employee (this is my 3rd week). I have 15 years previous banking experience in almost every department but never in compliance. Where should I start?
11/17/2003
We have a procedure to review unusual activity in employee's accounts on a regular basis. In addition, if we have a suspicion regarding a teller, we have reviewed account activity for that teller. Are there any privacy rules which would restrict our ability to review our employee's account information? Also, is there any consent required by the employee when they begin employment?
11/01/2003
One of the most interesting and revealing panels at the ABA/ABA conference was a discussion on Suspicious Activity Reporting, including when and how to file SARs.