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Reg E Dispute for Store Credit Card

04/22/2013

An individual has a store credit card at a department store, they go to the department store and make a payment using their debit card. They throw away the receipt. The payment has not posted to their department store account but we can see it debited from their bank account. They are getting the run around with the department store about finding the payment. They want to file a Reg E dispute. Does this transaction qualify as unauthorized?

How to Fill Out New CTR for Business Deposit

04/22/2013

I am trying to fill out the new CTR form and do not know how to do the boxes and blanks when a person comes into the bank and makes a deposit for a business. On the old form, we put the business name and EIN in the PART 1 section A and then put the person who conducted the transaction in Section B of Part 1. The new form #20 - is this info on the person that actually makes the deposit? I would think I check box 2c but then I do not know where to put the employee's info. I see the + - buttons at the top but do not know if this is when you use them. Any help would be great.

Violation of Reg O Executive Officer Mortgage Prop

04/15/2013

Regulation O-we have an executive officer who has a first lien mortgage on his primary residence. He thought this residence was sold, and purchased another property which he mortgaged with us. The first property sale fell through so currently both properties are on the bank's books. I assume we are in violation but would like some verification.

Loan Rescindable if No Transfer of Title?

04/15/2013

A borrower already owns his land. We give a construction loan and in a second transaction, we payoff construction loan with permanent financing. Is this loan rescindable due to the borrower already owing land and no transfer of title takes place?

Eligible for 6% Rate As Result of New Active Duty

04/15/2013

If an individual is already on active duty (either regular component or an activated Guard/Reservist) when they obtain a loan, separate or get released, then reenlist or get recalled to active duty, are they eligible for the 6% rate as result of the new period of active duty (even though they were active duty when the originally obtained the loan?

What Is Considered Close Proximity Reg E?

04/08/2013

If a customer opens a new account and is given Reg E disclosures at that time and later requests an ATM or debit card, do disclosures need to be provided again with the card even if they are the same as previously provided? What is considered close proximity?

Instructions On How to Complete Amended CTRs

04/08/2013

I just received two amended CTRs I had filed on 9.11.11 before they changed the rules for amended CTRS. At the time I attached a amended form with just the information that was incorrect on the original CTR. The rule changed on 10.31.11 stating that you made out a complete new CTR indicate it as amends prior report. So now it is 2013 and I have two CTRs to try to efile and can't find any instructions anywhere on how to do this. I tried to file FinCen CTR but it asks for a DOC # 14 numbers long; which of course I do not have. Do you have any idea where to find the documentation to show how to do this?

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Records retention and canceled remittance transfer

08/18/2024

Regarding a cancellation request of a consumer foreign remittance transfer - are there any document retention requirements related to the canceled wire transfer request? Is the FI required to retain a copy of the wire transfer request form or any other documentation related to the transaction since it never occurred if canceled within the 30-minute window? Our bank has a log to record all canceled international wire transfer requests, but that is the only documentation.

Completing CTRs on a business account

08/18/2024

When filing a CTR on a business deposit, do you include everyone on the account like you would a personal CTR or just the actual conductor?

Subpoena/summons investigations results and SAR filing

08/11/2024

Our BSA Officer manages our bank’s filing of Suspicious Activity Reports (SARs) with FinCEN. She has asked to include in our policy for managing summonses, subpoenas and similar legal documents a requirement that she be notified of any suspect activity that might be turned up in searches in response to those documents. Is that allowed?

Recognizing recurring and non-recurring debit card

08/11/2024

Can a merchant force a debit card transaction by claiming that the transaction is a recurring transaction event though it's not? For example, the customer opted out of overdraft service for ATM and one-time POS debit card transactions, but a merchant forced the transaction by claiming it's recurring.

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