03/31/2008
I plan to include a recommendation in my annual report to change the current reporting structure for the Security Officer. Presently, I report to the VP of Retail Operations. I am seeking references to cite that advise the bank security reporting structure should be in other areas such a finance, risk, administration, but not through retail because of the apparent potential for downward influences and the need for independence.
03/17/2008
I am fairly new to the deposit compliance arena. Under the advertising section of Reg DD, there are exemptions for certain types of media (<a href="http://www.bankersonline.com/regs/230/230-8.html">230.8(e)</a>). One of these exemptions is broadcast or electronic media, such as television or radio. Would an advertisement on our bank's website be categorized as electronic media, and thus exempt from certain disclosure requirements, or would it be considered just like print media and thus be subject to all requirements of <a href="http://www.bankersonline.com/regs/230/230-8.html">230.8(c)</a>? I think that it should be treated just like print media, but I am having a difficult time finding any regulatory guidance to either confirm or refute this.
01/21/2008
I’m an operations specialist and I was reading the article <a href="http://www.bankersonline.com/compliance/mbg_banktrapped.html">"Bank Trapped in RFPA Violation Through Army Subpoena"</a>. We were then going through our own privacy policy and realized that we did not know what a certificate of compliance looked like or what is needed to be included in it to cover the bank legally. Who in a government agency is allowed to sign off on the certificate of compliance? I was hoping you might be able to tell me what all is in the certificate or be able to point me to an example of what one might look like.
12/10/2007
How in-depth should the training be for the Board of Directors in BSA? Is a general overview of BSA/AML/CIP along with an overview of the procedures in place sufficient for compliance?
11/26/2007
We are in disagreement on Reg CC. One person reads Reg CC to state that all new account holds should fall off the ninth business day. Someone else reads that as only stating next day items as falling off on the ninth business day and local or nonlocal can be held till the eleventh business day. Which one is correct? Also, is there an exact way to train Reg CC? One trainer trains on a two day hold, counting the day after the deposit is made and then backing up a day for availability. (Deposit made on Monday, count Tuesday, Wednesday the backing up and funds fall off on Tuesday available Wednesday.) Another trainer trains counting the day of the deposit then funds fall off the night of that second day. (Deposit on Monday: count Monday, Tuesday and funds available on Wednesday.) Both outcomes come out the same, but we are wondering if the Reg would lean one way or another.
10/15/2007
Believe it or not, we do not have free checking yet. We have realized the need to put together a free checking account - not specific to age - and we are wondering what are the can do's, have to do's, and the don't do's are with establishing such an account. Your thoughts are appreciated.
05/21/2007
What is our liability if we issue a debit card to a business customer? If our card has a MasterCard logo, do we have to go by MasterCard rules? Are we in violation of any Regulation if we disclose to the customer that they will take all the liability?
05/07/2007
I am an auditor of a bank and did the branch audit yesterday. What are the requirements under CRA for the notice to be posted in a branch of a bank which is OTS regulated? I have a copy of the notice and want to make sure that it complies with the Reg.
01/08/2007
May we pull a credit report for an employee at the request of the employee?
03/20/2006
I am looking for a CRA Officer Policy and Procedures. Something that spells out what this person holding the title of CRA Officer should be doing.