08/17/2009
Do tellers need to run an OFAC check on a non-customer that comes in to cash a check on a customer’s account? The checks range anywhere from $5.00 to over $2500.00.
12/15/2008
Can the bank pay a teller a referral fee when a first mortgage purchase or refinance closes without fear of a RESPA violation?
11/17/2008
We would like to train our tellers on cross selling bank products. What are some compliance issues that the tellers need to be aware of when mentioning various products to customers?
09/22/2008
What position (head teller, loan officer, etc.) of the bank would be the best candidate for our BSA officer? Would it be our compliance officer?
06/04/2007
One of our branches has a customer (a builder) writing large checks to their employees on a weekly basis ($5k-$7k). The builder comes in with the employee to cash the check. The employee endorses first, then the builder endorses and cashes the check. The builder is a known customer, so the tellers do not get identification on him and since he endorses after the payee they are not getting the payee's identification. They are, however, checking the payee/employee against OFAC. Bank policy states that we check OFAC on all non-customer payees over $1000 and record identification on non-customers and payees over $3000. I am getting a match on two of the three employees. I am 90% sure that it is a false positive, but I cannot confirm or deny it is a valid hit unless I can compare their identification information to the hit. The branches administrator was notified that the branch is not following bank policy and that identification needs to be obtained on the payees. The branch defends their actions stating that, technically, they are not making an exception since the employee and builder are presenting on-us checks we are able to verify funds and also that the last endorser is vouching for the non-customer. I understand their concern because it is technically true, but as the Compliance Officer I also understand that, per OFAC, banks must block transactions that are by or on behalf of a blocked individual or entity. If this branch continues to willfully ignore the intent of the customer, which is to give money to this employee, we will end up with severe penalties if the payee is found to be a blocked individual. This is a risk I would rather the bank not take. Can you shed some light on the subject?
05/21/2007
I have been newly appointed to a bank Board of Directors and have little banking knowledge. I have been approached by one of our tellers with a concern about CTRs. It seems that on a regular basis (couple times a month) a customer comes into the bank with two checks around $6500.00 each and has them cashed. One is in his name the other is in his father’s name. Each time he is alone and walks out of the bank with around $13,500.00 cash. My teller is afraid that this is a BSA violation. Is this a violation? Would this at least warrant a Suspicious Activity Report?
09/04/2006
When must a hold be placed on an account for Reg CC? We are considering not allowing tellers to fill out the hold form, and have them done in the bookkeeping department to decrease the errors. Does the hold have to be filled out at the teller window and given to the customer and when processing the night depository?
04/03/2006
Can a hold be placed on a cashier's check (not one issued by us)? If not, and the check is returned to us as counterfeit, forged, etc. what should be done? How can we protect our bank?
09/01/2005
07/01/2005
About this time every year comes a contradictory phenomena known as "summer help".