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?
11/12/2007
Our internal auditor recommended adding policies and procedures for monitoring safe deposit box and ATM activity to our BSA Policy. I am having trouble finding any agency recommendations for this activity. Do you know where they can be located?
10/15/2007
Is there any type of guidance which says what should be stated in each employee's job description and evaluation form with regard to BSA/AML?
10/01/2007
Is it a requirement to send privacy notices to dormant DDA accounts?
07/09/2007
We are having a misunderstanding at my financial institution about the USA PATRIOT Act. We were first opening corporate accounts and gathering identification documentation and social security numbers on all the signers on corporate accounts. We were then instructed that it was unnecessary to obtain this information on the signers. Then about a year later we were instructed that the USA PATRIOT Act does require us to get this information. Does BSA or the PATRIOT Act require financial institutions to get ID for signers on corporate accounts as of 2007? If it does not, where can I find this information?
05/21/2007
I have been newly appointed to a bank Board of Directors and have little banking knowledge. I have been approached by one of our tellers with a concern about CTRs. It seems that on a regular basis (couple times a month) a customer comes into the bank with two checks around $6500.00 each and has them cashed. One is in his name the other is in his father’s name. Each time he is alone and walks out of the bank with around $13,500.00 cash. My teller is afraid that this is a BSA violation. Is this a violation? Would this at least warrant a Suspicious Activity Report?
04/30/2007
If two individuals have equal credit and other factors and one is granted a loan due to a non-bank related personal or business relationship with a bank officer, is this considered discriminatory from a fair lending/HMDA standpoint?
01/22/2007
What is the law/reg regarding overdrafts on bank employee checking accounts? From time to time we won't charge a good customer (long time customers who rarely have overdrafts) an overdraft fee. Since we do this for some customers can we do the same for a bank employee?
12/11/2006
On HELOCs and fixed HEs, if the property is in a flood zone, are there any special exemptions from tracking flood insurance for these customers? Do you assume the first mortgage holder will monitor and escrow for insurance coverage? Since we do not escrow for second mortgage loans, how can I effectively guarantee that the customer or first mortgage holder is keeping insurance in force?
11/20/2006
I attended a tele-seminar on 9/11/06 with Jack Holzknecht about Red Flag Guidelines; We just had an audit and we received a write up for not having any formal procedures in place to ensure identity of a customer requesting credit if a fraud alert appears on the customer's credit report. The recommendation read, "To mitigate fraud risk and ensure the proper identity, formal procedures should be created and implemented. Procedures may include additional steps for identification, additional security questions, as well as additional documentation to evidence of proof." If the Red Flag Guidelines are not finalized yet, how can we still get written up for it? Should the recommended policies be in place already even though there has been no Final Rule released?