Most Popular Compliance Content
HOAs & the USA Patriot Act
03/31/2008
An issue has arisen at my bank concerning the need for a signatory on a homeowners association account to submit his social security number. My bank's BSA Officer believes that he must do so. I am not so sure. This individual has no personal accounts with our bank, but is listed as a signatory on two accounts dealing with homeowner's associations. The person in question refuses to give his social security number. How are HOAs classified for purposes of the USA Patriot Act? It's my understanding that the HOA is the owner of the account. I know that the signatory situation was in the proposed rules, but not the final ones. I would appreciate it if someone could provide me with some guidance.
Gift Cards - Monetary Instruments?
03/31/2008
Are gift cards still not considered monetary instruments? Is this something that is coming in the future?
HMDA Reportable - Tax Saver
03/24/2008
Is a refinance of a tax saver loan HMDA reportable?
Change in Branch Bank's Operating Hours
03/24/2008
What disclosures are required for changing a branch's hours? Specifically having one branch not open on Saturday when only the drive through was open so it's not a banking day for Reg CC.
The Great Debate: Credit or Public Records Data
03/24/2008
Should my bank use an identity verification solution based on credit data or public records data?