09/20/2004
What is considered adequate training under the Bank Secrecy Act for bank employees? Might this vary based on their duties?
09/06/2004
Our tellers will be new to seeing substitute checks, and now customers will be trying to deposit substitute checks that have been returned to them in the form of a chargeback. One suggestion was to send all 'returned' substitute checks for collections from the other banks, but that seems excessive. How will our tellers recognize a returned substitute check, and what recommendations do you have for handling any that are redeposited?
09/06/2004
Our tellers will be new to seeing substitute checks, and now customers will be trying to deposit substitute checks that have been returned to them in the form of a chargeback. One suggestion was to send all 'returned' substitute checks for collections from the other banks, but that seems excessive. How will our tellers recognize a returned substitute check, and what recommendations do you have for handling any that are redeposited?
09/01/2004
What a year this has been! Rules and regulatory concerns keep coming - and coming, and coming.
08/02/2004
Our bank offers nondeposit investment products through a third party. This party has prepared posters and wants our bank to display them at our teller windows, new account desks and the customer counter in the lobby. I was under the impression that this was not permitted and actually had an examiner take a poster off of our customer counter in the lobby. However, I can't seem to find this in writing anywhere. I can see where it states that tellers should not, while located in the routine deposit-taking area, make general or specific investment recommendations regarding nondeposit products, but it does not specifically state that brochures/posters cannot be located in these areas. Could you please advise me on this issue?
11/03/2003
My CTR question is this: Husband makes a deposit to his individual account. Later the same day, wife makes a deposit to her joint account with the husband. Individually, neither transaction is reportable. Aggregated, they exceed $10,000 and the husband can benefit from the whole. Do we need to file a CTR and if we do, can you help us out with the technicalities? Do we check multiple persons, multiple transactions? And what do we do about the information we don't have on file (for example, driver's license numbers and occupations)? We caught this on a system report that monitors daily activity by social security number. Two different tellers were involved and had no knowledge on the day of activity.
10/20/2003
Our tellers do an OFAC inquiry on the payee of a cashier's check before issuing it. What is our responsibility in the case of money orders? Many customers want the payee left blank.
10/06/2003
Does the term "multiple transactions" on the CTR form mean: 1) that more than 1 account number was used in the transactions, or 2) there is one account number and multiple transactions were conducted on that account?
04/01/2003
The Federal Reserve Board has reached a consent agreement with the Barnes Banking Company of Kaysville, Utah. The agreement states the goal of maintaining financial soundness.
03/03/2003
When a customer deposits a check into his/her account, our tellers are instructed to write the customer's account number on the back of the check. We had a customer who was concerned about the person who had written him that check having access to his account number if he received the cancelled check back. Is it a violation of customer privacy laws to write their account number on the back of checks they deposit?