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FFIEC Exam Manual-Politically Exposed Persons

10/28/2018

The FFIEC Exam Manual refers to Politically Exposed Persons, as a "senior foreign political figure". We have Examiners here, who also have stated that they are only foreign political figures (and their families, close friends, & associates, etc...). But, we had a State of Arkansas House of Representative come up as a "hit" on the Enhanced Politically Exposed Persons (PEP) list when we ran them through the OFAC section of Chexsystems. So, I am just looking for some clarification or guidance on this.

OFAC and Account Closing

10/14/2018

If the OFAC list now contains a name that matches our customer’s name, should we immediately close the account?

Run OFAC After The Deposit Account Is Opened?

09/23/2018

When opening a new deposit account, not current customer, do we have to run the OFAC while the customer is sitting at our desk or can we run it after the account is opened? Do examiners have a preference on this?bri

LEIs or not?

07/22/2018

What is an LEI? Do we have to use it to establish beneficial ownership certification?

BSA Hold On Incoming Wire for More Information

10/29/2017

When BSA holds an incoming wire because they need more information such as invoices, It is our procedure to send a service message to the originating bank and ask for that required info. Sometimes, we are asked to contact the customer and ask for that information from the customer. Is that against any violations or do you think that could offend the customer in any way? Should a specific dept like BSA, contact the customer for that information to avoid having a dept like customer service, that doesn't have any knowledge on that, say something incorrect?

OFAC testing frequency

05/07/2017

With respect to testing (running the OFAC list against your technology filters), how often should we be testing given the frequency of the updates to the OFAC list?

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Member FDIC on the WWW

11/24/2024

Is there an FDIC requirement that the "Member FDIC" logo be on all our pages and link to the FDIC website?

Carte blanche to an Authorized Signer

11/24/2024

What are your thoughts on allowing customers to give an authorized signer access to their online banking and/or approving them to have a debit card? Would it make a difference if there is a form signed by the customer providing authroization and acceptance of liability for the transactions the signer conducts?

Audit checklist for bank as mortgage loan broker

11/17/2024

I am looking for a checklist that auditors would use when doing an audit on a brokered mortgage, specifically when the bank is acting as the broker. Can anyone give me a suggestion as towhere to find one? I have been searching the internet but have not really found anything that would help me with this.

Data breach and card reissuing

11/17/2024

We have been notified by Mastercard of a data breach and need to inform our customers who were impacted by this incident. In previous financial institutions where I have worked, we typically send a letter to notify customers about the card compromise. This letter includes the date we will be closing their card and informs them that a new card will be issued. My question is regarding the regulations surrounding this process: Can customers choose to keep their card active? If so, where does the liability lie if they experience fraud in the future? I am looking for a regulation or a Mastercard rule to implement a formal policy, as there isn't one currently in place at my current financial institution.

Deceased Joint Accountholder Process

11/10/2024

Is this correct? Surviving joint account owner(s) can continue to use a deposit account as normal. The decedent will need to be removed from any deposit account they are an owner of. We thought the account had to be closed and another one opened but I'm hearing conflicting opinions.

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