Latest Compliance - Employee Topics

Monetary Penalties For Unauthorized Credit Reports

02/04/2002

Is the only $$ penalty for pulling an unauthorized credit report $1000?

Information Security: What do I need to know?

02/04/2002

What are the information security needs of a bank?Which laws/guidelines deal with information security needs of the bank?What are the steps involved in designing a security policy for a bank?

Compliance Management: Want to Hire a Regulator?

01/01/2002

Photocopying A Driver's License For Identification

12/03/2001

Is it allowable to xerox a person's driver's license photo? Some tellers were doing this for non-customers cashing checks at our bank, but another employee says we cannot do that.

Reg CC: Hold Notice Notification Requirements

12/03/2001

I had a customer tell me that I was out of Compliance on Reg CC because she was not notified at time of deposit of a hold being placed. It is my understanding that we have 24 hours to put a Notice of Hold in the mail to the customer. We did not notify the customer at time of deposit due to large items being reviewed by myself at a later time in the day.

SSN As Employee Identification

12/03/2001

We currently use an employee's social security number as their teller id number. Is this a privacy issue? Is this a misuse of the SSN?

Convicts And the Contents Of Safe Deposit Boxes

12/03/2001

We have a customer that opened a safe deposit box with our bank. Two months later he was arrested in another state for armed robbery. No other details.The rental was past due and we sent a certified letter to his last knowaddress. Rent was past due 5 years. Had not heard anything from customerfrom 1993 until this October. He attempted to reclaim the items from thedrilled box. All identification had expired (he had been in prison all thattime). We refused since all identification was expired and we had no proofit was him. He has now contacted an attorney and is demanding the contents.During the course of talking with the branch in trying to identify theperson, a copy of the contents was sent to my attention. Should we file aSAR since we know he served time for armed robbery and the contents arenumerous pieces of jewelry (Rolex watches, loose diamonds, diamond pendants,12 rings, etc.). This is a new one for me.

Liability For Stolen Business Checks

11/05/2001

A longtime customer's employee has stolen checks from his business account. The employee was not an authorized signer on the account. Isn't there a provision in the UCC that says the bank is not liable for unauthorized signatures if the suspect is an employee?

Reg CC & Depositary Bank ATM Deposits

11/05/2001

I'm reading Reg CC and noticed it adressed "nonproprietary ATMs" but I'm wondering what the rules are for ATMs owned by the depository bank. Right now we have next day availability for ALL deposits and we're getting BURNED! We looking at changing some of our policies and the main change will come from the ATM side. If a customer makes a $500.00 (cash) deposit in an ATM owned by us how long can we hold the availability of that money? Same question using a $500.00 local check and a $500.00 nonlocal check (seperate deposits). Correct me if I'm wrong but in all of the above examples if the deposits were made at an nonproprietary ATM we could hold the customers fund for up to 5 business days...

Restrictive Endorsements

10/01/2001

We had a check that was payable to her and her husband into her individual account. On top of that mistake the teller accepted the check with "deposit only" on the back. The husband is now threatening legal action against us if he doesn't receive the funds and the wife has hired an attorney that says we cannot hold the funds in her account until this is settled. Can we hold the funds, they were deposited three months ago or do we not have the right to hold these funds, her attorney has sent a letter saying he is filing suit if we don't release the funds to her?