Most Popular Compliance Content
What is a facially neutral policy?
07/23/2023
What is a facially neutral policy?
Paying out CTR-able cash, sans SSN
07/23/2023
We have a non-banking client who received several checks from his deceased grandmother (our client) which total over $10K. He is traveling from KS to Fla to cash these checks. Our problem is that he doesn't have a Social Security Number. Can or should we cash the checks and create a CTR, or refuse him? He does have a DL. He lives off the grid....we will file a SAR for sure.
Insiders and Overdrafts
07/16/2023
An executive officer has a debit card transaction that has caused an overdraft. As to Reg O, we would pay and charge the fee. But as to Reg E he has opted out which means we would pay the item and not charge the fee. I don't know which Reg takes precedence. The account is overdrawn less than $100.
Donating Small Balances to Close
07/16/2023
Are depositors allowed to have the bank give away their small deposit balances tocharity? These would be deposits less than $1.00 and we'd allow them to direct this in writing or over the phone that they want the balance given to charity? As an example say the customer calls in to inquire on their balance and we tell them it is $0.12. They say "its ok, you can keep it." What if the account goes all the way to its escheatment date and a letter is sent and the customer again says "just keep the $0.12" because they are not interested in getting or cashing a check for that. Is such thing as a goodwill GL account allowed where these funds could be placed and donated to a charity? The funds would paid to a charity periodically or when a certain amount is reached in the account.. Is there any regulation addressing this?
Lobby Advertising
07/09/2023
We often have lobby posters advertising products, services, benefits like trips on a discounted price and others things on display so staff can answer questions on these and to promote these items. Do they require the general FDIC advertising statement>