Most Popular Compliance Content
Was this check altered or forged, and why does it
05/19/2024
Our customer issued a check to an insurance company. The item was altered (washed), made payable to a new payee, and deposited into that payee's account. We were outside of the 30 day return window and went bank to bank to recover the funds. We are being told that our claim is being denied due to the following: "The check contains a forged maker signature. This is not an altered item and there is no breach under UCC § 4-208. Our review of other items involving this drawer demonstrates that this check was not signed by an authorized signer of the drawer. As a result, we decline to pay the claim." How would they as the depositary bank be in any position to tell us that our customers signature is forged? It was not forged. The payee line was altered. What are our rights to refute their denial so that we can reclaim the money?
Is checking online banking, being aware of a loss?
05/12/2024
Can a bank use the customer’s history of access to their online banking, to determine when the customer was aware of a loss such as an unauthorized electronic funds transfer?
What changed on Reg CC Exams
05/12/2024
I see from the BOL Daily Compliance Briefing that the FDIC Exam Manual has been updated. Specifically it was noted, "Expedited Funds Availability Act (VI-1.1): Updated with technical changes related to regulatory dollar-amount thresholds and large deposit hold times." I've compared the old and new versions of the part of the Reg that is referenced and am hoping someone can point out to be specifically what has changed and what the new expectations are from the revision? I don't know that it will change our process because we already make funds available a little earlier than required in most cases and our disclosures accurately state this, but I want to be sure.
Digital Signage Requirements
05/05/2024
The new FDIC Official Digital Sign requirement has a specific wordmark size that is not format friendly when displayed in mobile banking. Can the sizing be adjusted for the screen or must the text be wrapped for full display? Will resizing to accommodate the screen impact compliance?
MSB, But Not at our Bank
05/05/2024
If our institution banks an entity that is registered as an MSB but, the entity does not hold their MSB account at our institution, are we still required to complete a full MSB high risk review or even have them marked as an MSB?