01/14/2013
If a bank, in the normal course of business does not regularly supply information to a CRA on consumers, are they required to provide new information as a result of an address discrepancy under Fact Act ID Theft?
12/24/2012
Compliance Related
Attention Deficit Disorder
by Mary Beth Guard
Recently, I was diagnosed with CRADD:
12/10/2012
Under CIP, if we have a current customer whose government issued ID has expired are we required to obtain a current ID before doing any transactions for that customer?
11/05/2012
If a check is cashed at a check cashing establishment, what are the KYC requirement for that establishment? If we placed a stop on a check can they come back to us stating that they had obtained ID and it was a "known" customer? What if the ID used was false - ID theft? Are they not responsible for negotiating the item?
10/08/2012
One of our loan officers did a loan for a new customer who has recently been married. The loan officer did the loan in the Customer's married name but took her ID with her maiden name. Her CIP will not match the name on the loan. Will the bank be out of compliance with the examiners?
09/17/2012
Is there a requirement that lending agencies require proof of identity by coming in in person and giving a copy of a state issued ID before a loan is issued?
08/06/2012
For a business checking with husband and wife using a Federal ID tax number, can they use business interest checking?
06/04/2012
CIP requires that we obtain the customer's tax identification number. Is it required to verify the customer's tax identification number? In other words, should the bank require the customer/or business to provide proof of their tax identification number?
04/30/2012
On a Broker application, is the investor allowed to correct the Government Monitoring Information if what is marked is not consistent with the picture ID in the file?
04/02/2012
A customer notified the bank of forgery on checks drawn on our bank. These were counterfeit checks with a forged signature which were cashed by our tellers. The tellers exercised ordinary care: verified the signature card, obtained proper ID and a thumbprint. But these counterfeit checks were too good and almost identical to the real thing. The customer notified us within the correct time; therefore, we refunded the money. A state police officer said that the bank is not the victim; the customer is the victim, so we didn't have to refund their money. The customer is victim of check fraud, not us. I realized that the police officer may not know of banking regulations, but is there any truth to this? I thought, per the UCC, that the Bank is liable for this. We cashed the checks and they had a forged signature; therefore, we take the loss.