12/05/2011
Is there any regulation that requires obtaining/retaining a copy of a social security number and drivers license for any and all checks cashed for a non-customer, whether it is an on-us check or a check from a non-customer to an existing bank customer? We do understand the need to pull OFAC on all transactions that involve a non-customer no matter the amount of the check. It is very time consuming to make copies of IDs and the checks. Are examiners going to the extreme? If we check identification, it seems that with the OFAC that should suffice. Are all banks required to do this now?
12/05/2011
Can we pull a credit report on a customer without their consent? We have a customer who wants to consolidate some credit card debt. We told her that she needed a co-signer. She gave us her husband's social security number. Can we pull a credit report without his authorization?
11/07/2011
Is there a regulation for national banks dealing with the Bank Protection Act? I know Reg H is for state chartered banks.
10/03/2011
Is it proper for a bank to reclaim a customer's social security funds that were direct deposited on June 3 if the person died on June 2?
10/03/2011
Are we legally required to list the complete account number on any bank mailing (overdraft notices, statements or any correspondence to a customer)? Are we allowed to suspend the first 5 of our 10 digits?
08/22/2011
Can an UTMA be opened with a ATIN (Adoption Taxpayer Identification Number) until the Social Security Number is issued? If so, are we required to withhold?
07/18/2011
I recently attended a Harland Laser Pro Regional Conference. It was indicated that the SAFE ACT states that mortgage lenders must register for a NMLSR. Does this include loan officers that just take Home Equity Loan and HELOC applications?
07/04/2011
A loan is secured by several vacant lots and a mobile home is to be moved to one of those lots but will NOT be permanently affixed. Is a flood determination required?
05/16/2011
A spouse's name is not on any real estate loan documents except for the mortgage for homestead rights. Should the spouse's name be on the right of rescission?
04/25/2011
During one of our recent exams, it was suggested by the examiners that we open accounts online (which surprised us); they would like us to phase out our brokered deposits and felt we could replace these deposits by opening accounts online. I have been trying to gather some information on what is involved in opening accounts online, in particular the risks involved; how to handle CIP, how to handle disclosures and how to obtain the initial deposit. I put out a question on Banker Threads, but did not receive much information. Can you direct me to any information that would help?Also, our president would like me to do a comparison to Free Checking - the pros and cons vs online accounts. While I have not experienced opening accounts online, I have been at a bank (some years ago) that offered free checking and we had a good experience. Few losses, customers really liked not having to worry about a maintenance fee, and the average balance tended to be around $3,000. I was wondering if you could direct me to any other sources that might be able to provide information or statistics on free checking?