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Latest Compliance - Security Topics

Use Escrow for Funds if Loan is 30 Days Delinquent

07/02/2012

If a loan is more than 30 days delinquent, can we withdraw funds from their escrow account to make their payment? Are we also obligated to pay their property taxes if there are no escrow funds available to do so? Also, please let me know where I can find the answer in the regs. I've searched RESPA with no luck so I'd like to know how to be better at researching.

Theft Involving ATM Considered a Reg E Claim?

06/18/2012

This is in regards to Reg E. Say there is a member who went to an ATM and tried to deposit a check but was unsuccessful. Without cancelling the transaction or pushing "no further transactions" and receiving the card back, the member walks away from the ATM. During this time there had been another person waiting in line to use the ATM. Well as soon as the member left, the other person came up to use the ATM but noticed that the previous person hadn't cancelled the transaction and the ATM still waiting for further instructions on what to do next. The person withdrew $300.00 and then tried to withdraw more but was unsuccessful. Is this a Reg E claim? Obviously it is theft but I don't think it is Reg E due to it not being an error that the credit union made but the member made. I know that the Reg protects the member from being negligent but its not like the member lost the card with the PIN written on the card. The member never finished the transaction and walked away with the card still in the ATM waiting for further instructions.

How to Report Commercial Buildings on LAR

05/21/2012

I have a loan for 3.7 million secured by 2 commercial buildings and (8) 4-plexes. We split our entries on the LAR. Would I divide the 3.7 million by 8 (the dwellings)and report as 8 entries on the LAR?

HMDA How to Report Loan for Apartment Complex

02/20/2012

I have a HMDA question. I have loan that is to purchase an apartment complex, 60 apartments in 5 separate buildings. Do I report this all at once or do I report each building separately?

Loan Secured by 3 Properties-Which to Report?

02/06/2012

I have a loan where the purpose is to purchase a residential dwelling. The loan is being secured by three other properties that does not include the property being purchased. Which property do I report on for HMDA?

Release of Financial Information for Subpoena

01/09/2012

What is the minimum amount of identifying information that the issuer of the subpoena must supply to the bank in order for the bank to be legally able to release financial information? Is it a matter of bank policy or federal regulation?

List of Required Officer Positions

01/09/2012

Can you provide a list of required officer positions? Are these requirements listed in the regulations or are they simply suggestions? I'm trying to determine which officer positions are mandatory for compliance so I may pass this information on to Executive Management.

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Records retention and canceled remittance transfer

08/18/2024

Regarding a cancellation request of a consumer foreign remittance transfer - are there any document retention requirements related to the canceled wire transfer request? Is the FI required to retain a copy of the wire transfer request form or any other documentation related to the transaction since it never occurred if canceled within the 30-minute window? Our bank has a log to record all canceled international wire transfer requests, but that is the only documentation.

Completing CTRs on a business account

08/18/2024

When filing a CTR on a business deposit, do you include everyone on the account like you would a personal CTR or just the actual conductor?

Recognizing recurring and non-recurring debit card

08/11/2024

Can a merchant force a debit card transaction by claiming that the transaction is a recurring transaction event though it's not? For example, the customer opted out of overdraft service for ATM and one-time POS debit card transactions, but a merchant forced the transaction by claiming it's recurring.

Subpoena/summons investigations results and SAR filing

08/11/2024

Our BSA Officer manages our bank’s filing of Suspicious Activity Reports (SARs) with FinCEN. She has asked to include in our policy for managing summonses, subpoenas and similar legal documents a requirement that she be notified of any suspect activity that might be turned up in searches in response to those documents. Is that allowed?

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