Most Popular Compliance Content
Which credit bureau to disclose
02/12/2017
If you use a vendor that provides credit scores from all 3 bureaus and you only use the score/reasons from one bureau for the denial, do you use that specific bureau's name and address or the actual vendor that supplied the report for your adverse action notice?
Wire Transfers w/o INC, LLC, CORP Included (Risks)
02/12/2017
We have been receiving several incoming wires sent to the beneficiary name (business account) without the INC, LLC, CORP included. Will this cause an issue or will it apply to any risks that we should be aware of at this point?
List of High Risk Customers Regulation (AML/BSA)
02/12/2017
What bank regulation is it that requires them to develop a list of high risk customers? OFAC?
Reg CC Extended Hold Notices
02/12/2017
Our front line staff creates the hold notice and then sends to the Fraud Dept to review and put on the system. Often times the front line does the Hold Notice Wrong. If we change the Hold Notice we send the customer a new one. If we decide the hold is not necessary are we required to send notification to the customer informing them their funds are available sooner then we originally informed them?
Parameters On Banks Giving Bonuses to Customers
02/05/2017
I would like to know what (if any) parameters surround banks giving bonuses to customers. I am familiar with the typical $10 refer a friend program but I am looking at amounts exceeding $10,000 on more than one occasion. The bonus or referral fee (I’m not sure how it is categorized) is paid based on how many people sign up for pre-paid cards on a monthly basis. I was able to find this article (noted below) but I think it misses the mark regarding what I’m looking for. The reason why I saved this article was the bonus payments I’m referring to do not fall within the guidelines of numbers 1-3. “Now let’s look specifically at Regulation Q and what it has to say about paying a bonus on an account. In fact, §217.101 is specifically titled “Premiums on Deposits.” (a) Section 19(i) of the Federal Reserve Act and 217.3 of Regulation Q prohibits a member bank from paying interest on a demand deposit. Premiums, whether in the form of merchandise, credit, or cash, given by a member bank to a depositor will be regarded as an advertising or promotional expense rather than a payment of interest if: (1) The premium is given to a depositor only at the time of the opening of a new account or an addition to an existing account; (2) No more than two premiums per account are given within a 12–month period; and (3) The value of the premium or, in the case, of articles of merchandise, the total cost (including taxes, shipping, warehousing, packaging, and handling costs) does not exceed $10 for deposits of less than $5,000 or $20 for deposits of $5,000 or more. “ http://www.bankerscompliance.com/~bcc/assets/files/articles/Bonus_on_Acct_+_Flowchart.pdf