12/17/2012
This question is in regards to the SAFE Act and disclosure of the MLO's unique identifier with the initial written communication. If loan is made to an employee of Sr. Management and the MLO is Sr. Management as well, does the requirement still apply? Obviously these employees know each other well, and since the unique identifier is a tool for customers to get info about the MLO would the disclosure of the unique identifier be relevant in this case? Would an examiner cite an Institution for not having disclosed the unique identifier on initial written communication?
11/12/2012
Are there any specific regulations that state who would have the authority within a financial institution who can deny credit? Should that individual have the lending authority to approve what credit is being denied? Ex. customer service rep denies credit applications but that customer service rep has NO lending authority.
07/09/2012
Is a charged-off deposit account considered an on going relationship for CIP purposes? Can we re-open a charged-off account without re-CIP?
06/11/2012
We are being told by our internal auditors that a customer in which we have CTR exempted should be removed from exemption status due to negative information that they found regarding the customer that they found on an Internet search that dates back to 2000. When we performed our due diligence to exempt the customer last year we performed our due diligence and maintained records in accordance with FFIEC BSA/AML CTR exemption guidelines. There were no abnormalities noted at that time. The reasoning our auditors are referencing is that this customer poses a higher risk and should be removed as "Best Practices". Has anyone every experienced this?
04/30/2012
Under Reg GG, how does Internal Audit go about setting up a review that will satisfy the regulators?
01/09/2012
Can you provide a list of required officer positions? Are these requirements listed in the regulations or are they simply suggestions? I'm trying to determine which officer positions are mandatory for compliance so I may pass this information on to Executive Management.
11/28/2011
Can a business owner cash payroll checks against his business account that are made out to his employees? The checks that are being cashed are from the same business account name but drawn on another bank.
10/24/2011
I'm trying to determine the differences between the US OFAC SDN lists compared to the UN Sanctions Lists. Is the SDN list more comprehensive than the UN list? Does the SDN list also include the UN sanctions lists?
10/24/2011
Does a check cashing MSB have to check names against the OFAC list? The MSB does no other MSB activities but check cashing. I have called FinCen numerous times and they have not returned my call. Someone at OFAC referred me to Title 31 which also did not address or answer my question.
10/03/2011
We are looking at purchasing Small Business loans from a third party. Management would like to advertise the third party's product for small business loans to our customers. What compliance issues could the bank face by advertising their product?