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Latest Compliance - Power of Attorney Topics

POA Makes Withdrawals from PUTMA Account

08/23/2010

If a POA makes a reportable withdrawal for the custodian on a PUTMA account, we will put the custodian in Section A of the CTR and the POA in Section B. Do we also need to include the beneficiary of the PUTMA in another Section A? We don't know if the money is going to the beneficiary or not.

POA on a Revocable Trust Account

11/27/2006

Is it possible to have a revocable trust account where you have set up a person to be a power of attorney on the account along with the trustee (only 2 signers on account), where the POA is also a successor trustee?

Power of attorney and LLC

01/31/2005

I have a customer that has an LLC with a relative being the managing member and the customer is just a member. The customer has POA on the managing member. Can she come in and open the account without the managing member here or signing? Or should the LLC have to change the Articles to her being the managing member?

CIP & Mortgage Lenders

08/18/2003

The CIP ruling did not specifically address the mortgage lenders. How can we or when should we identify customers on mail applications, telephone applications or when the loan is being handled by a representative with a power of attorney and the borrower cannot be present?

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'Member FDIC' in trust department ads

10/13/2024

Our bank has a trust department and they want to run an advertisement. Does "Member FDIC" need to be included in the ad? The ad will state something like, "We can help you with your Trust and Estate Planning."

Unauthorized Authorized Debits

09/29/2024

If a customer authorizes someone to use their card and gives them the PIN for a specific transaction, and that someone uses the card for additional transactions that were not authorized by the customer, is their any negligence by the customer for giving the card and PIN for the first authorized transaction? What are the requirements according to Reg E ?

Are All Private ATM Owners Equal

09/29/2024

I have read through several articles on private ATM owners and the enhanced due diligence on these; however, none seem to call out private ATM owners that do not have access to fill the ATM. Would these customers have the same expectations? Would it be necessary to tag these customers, obtain contracts/agreements and do yearly reviews of activity?

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