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Latest Compliance - Operations Topics

Running OFAC On Non-Customers (Not FinCEN)

01/19/2015

We have been running OFAC on non customers, but not FinCEN. Do we have to build a CIF record or go to the FinCEN website? If go to the FinCEN website, how do you do it? I have tried and cannot find how to search.

Periodic Statement for Transfer of Interest COD

01/19/2015

Is it necessary to provide a customer with a periodic statement for a monthly transfer of interest from a certificate of deposit to one of their accounts at another financial institution?

Secretary Signature on Business Checking Accounts

11/05/2012

I have been instructed to obtain a "Secretary Signature" on all Business Checking accounts. Is this the law? Many accounts today do not have Secretary's. Please advise if this is a Compliance mandated requirement or an Operations Requirement or neither.

Interpretation of Reg D Number of Transfers Limit

01/23/2012

I feel that my bank's operations unit has misinterpreted the Reg D provision limiting the number of transfers. They read the cycle to include quarterly statements on savings accounts and limit the six transfers per quarter not monthly. The depositor is permitted or authorized to make up to six transfers or withdrawals per month or statement cycle of at least four weeks.

Corporation and LLC w/ Same Tax ID#

12/12/2011

We have a business customer that has a corporate account with a tax ID#. He is also a member/manager of an LLC that uses the same tax ID as the Inc. Both the Inc and the LLC have been filed with the state of WY. He is making deposits into the Inc. account but some of the checks are made payable to the LLC and some to the Inc. I thought that if you have an LLC and Inc. you would have to have a separate account for each entity. The customer tells us that he does not need a separate account as the LLC account conducts all business and operations through the corporate account. Is this a true statement?

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Lending newbie with operations background – I’m struggling!

04/23/2023

I recently accepted a new position at my bank in the lending department. I came from operations and wanted a change, but now my head is spinning! There are so many rules on the lending side, and I am struggling. How can I get on top of it all?

Requirement to Verify a Beneficiary

04/23/2023

Are there any specific requirements that we verify that a beneficiary is a natural person, charitable organization, or other non-profit entity for purposes of complying with 12 CFR 745.4(c)&(d) - beneficiary of a trust?

Optimizing complaint log use

04/16/2023

What is the most common way that banks record or log complaints and inquiries to have available when the examiners come in looking to see what we have?

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