Most Popular Compliance Content
New Fee - Disclosure Rules
04/02/2023
Our bank charges a telephone transfer fee. This was a new fee added recently. According to Reg E Section 1005.7(b)(5), we must disclose any fees for EFTs or the right to make transfers. I wasn't sure if the fees described in Reg DD applied to this type of transfer fee. Would we need to disclose this fee 21 days prior to the change?
What is Authorized Push Payment (APP) fraud?
04/02/2023
What is Authorized Push Payment (APP) fraud?
Spreadsheets for loan policy exception tracking
04/02/2023
What are some potential drawbacks to using spreadsheets to track loan policy exceptions?
Frequency of High-Risk Reviews
03/26/2023
How often do we need to review our high-risk customers?
Handling Deposits of MRB Staff
03/26/2023
A dispensary (Marijuana Related Business) just opened this month in town. We have two members (we are a credit union) that receive payroll from there (ACH). - Given their employer, is it illegal for them to bank with us? - Do we need to terminate our relationship with them? Our policy only states for MRB's that we would allow tier 2 and 3. Technically it is an individual, not a business though. Are we allowed to keep them? I know there are SARs we may have to file for MRB's (limited/terminated, etc.). If we keep thee depositors, do we have to file a SAR every 90 days on the individuals as long as they are employed at the dispensary? We understand there is a certain risk having them. There is really no guidance from FinCEN regarding employees of MRB's, just MRB's themselves. Any guidance would be greatly appreciated.