Most Popular Compliance Content
High Risk? Anybody or Nobody?
06/18/2023
Who is high risk for BSA?
Legal counsel is a control person for BOI?
06/11/2023
Is the company’s staff legal counsel considered a control person for beneficial ownership?
Is a wheel-spin game allowed?
06/11/2023
We have a “spin the wheel” promotion. To spin, a customer must donate $1 that the bank donates to a charity. All the prize amounts on the wheel are more than $1 therefore all customers will get more than they donate. The amount won is then sent to the customer via our e-wallet app. We set a certain number of spins and it is done on a first-come-first-served basis.
Required CTR Exemptions
06/04/2023
Are banks required to exempt customers for CTR filing limits? I've worked for banks in the past that never exempted anyone. We just filed CTR's on large cash transactions. So in short is there a regulation stating that banks need to exempt customers, or why is it done?
Rule Change - Reg Change?
06/04/2023
According to Reg D, "Savings deposit accounts are specifically excluded from the definition of transaction account, even though they permit third-party transfers, provided that the depository institution complies with the transfer and withdrawal limitations applicable to ‘‘savings deposits’’ under Regulation D." Since the Reg D transfer limitations have been lifted, does this now make a savings account a transaction account?