04/29/2013
An Office Worker is employed at Big Grocery, which is exempt from currency transaction reporting. She brings in a business deposit including $8,000 cash. She also deposits $5,000 cash in her personal savings account. Is a CTR required since she is a transactor on both deposits?
04/22/2013
I am seeking some guidance regarding the designation of exemption for a customer that mutually owns two businesses and conducts activity for both with our bank. He is a common owner listed on both accounts and therefore CTRs have been filed on both businesses on a single Currency Transaction Report by selecting the multiple persons and combining both businesses' aggregated transactions for reporting.The two businesses have separate accounts and tax ID numbers, the addresses and phone numbers listed are different as well. Transactions do not intermingle between the businesses and are clearly separated; the only common denominator is one of the principal owners of the businesses.When attempting to exempt the businesses can they both be combined under one Designation of Exemption? If not, only one of the businesses qualifies on its own to be exempt, would we be required to amend prior Currency Transaction Reports to separate the two businesses? Or have we been filing incorrectly to begin with?
04/08/2013
When a customer is negligent with the loss of their card, as in waiting 10 days to report, what is the liability the customer faces according to the Visa rules? I know Reg E is 2 business days @ 50 and up to 500.
03/25/2013
Under CRA, what constitutes a commercial or Industrial purpose? I have looked for a definition to no avail. Would this include a loan to a small business for a capital injection?
02/25/2013
In regards to HMDA reporting, how are we supposed to code an Interest Rate Reduction Loan (IRRL) where no income was required?
02/11/2013
A spouse dies on a jointly owned CD. Can the name of the deceased be removed and the CD continued to maturity? OR do you let it mature and then change the ownership? Is there a penalty for changing only the name due to the death?
02/04/2013
Are indirect auto finance companies required to comply with SARs reporting?
02/04/2013
I participated in a recent seminar where BOL Guru Dana Turner was the presenter. He mentioned that there might be a conflict of interest if the bank's Security Officer was also a director. I am in that position and I have discussed this with the Board/Executive Committee and was told today that they had talked with our bonding company and were told this was not an issue. What is the rational for ensuring that our Security Officer should be an employee, rather than a director?
01/14/2013
Currently, we don't require our non-resident alien accounts to have ITINs. My understanding is that a non-resident alien can receive an ITIN or SS# (in some cases). With this new reporting requirement of interest paid to non-resident aliens, will we need ITINs on all of our NRA accounts? Otherwise what number do we report them under on the 1042-S?
01/14/2013
If a bank, in the normal course of business does not regularly supply information to a CRA on consumers, are they required to provide new information as a result of an address discrepancy under Fact Act ID Theft?