Bio:
Barbara McGuire is Vice President and Bank Secrecy Officer for Central National Bank officially headquartered in Junction City, Kansas. She is located in Topeka, Kansas, at the bank's executive offices. Ms. McGuire is responsible for all aspects of the bank's bank secrecy and anti-money laundering program. She has 35 years of banking experience including assignments in retail loans and operations as well as residential mortgage areas. However, the last 20 years she has dedicated her efforts to general bank compliance and BSA compliance. In addition, she has spoken on a variety of compliance-related issues within the banking and public communities and was a guest speaker at the 2003 ABA Regulatory Compliance conference in Washington, D.C. Ms. McGuire is a past member of the ABA's compliance Executive Committee, the ABA Anti-Money Laundering Issues Group, Account Opening Best Practices Group, and Advisory Committees for ABA's Professional Development Tract brochure and Compliance Watch 2003. She is a graduate of both the ABA National Compliance School and the ABA Graduate School of Compliance Management. She received her bachelor's degree in business administration from National University in San Diego, California, and her master's degree in management from Bellevue University in Omaha, Nebraska.
Questions Answered
09/23/2013
I have an issue that some of our tellers are not understanding. Tell me from the compliance standpoint of CIP how this should be handled. We have always required ID on all people, customersif you do not know them and noncustomersno question. However, some tellers are not asking for ID on noncustomers because they have been coming into the bank for the last 5 years to cash their check so they do not get their ID. How do you suggest we handle this situation?
09/11/2006
What is the time period to wait before reopening a closed credit card account to be in compliance? (e.g. If it has been 6 months since it was closed then they must reapply with a complete application.)
09/11/2006
When a borrower wants to purchase a second home that is greater than 50 miles from their primary residence are their financing options mitigated? Does the 50 miles become a trigger point?
09/11/2006
Is it permissible to allow a customer to withdraw a portion of the principal amount of a Certificate of Deposit or change the term prior to the maturity date?
12/15/2003
We want to begin offering debit cards tied to home equity lines of credit. To do so, we must open a "dummy" checking account (a system requirement I think). Do we have to give normal checking account disclosures for this dummy account? I do believe we need to give Reg E disclosures, but am not sure about any of the others.
08/18/2003
Based on 31 CFR 103.22(c)(2), multiple currency transactions shall be treated as a single transaction if the bank has knowledge and result in either cash in or cash out totaling more than $10,000 during any one business day. Does this mean that if Customer A deposits (cash in) $9,000.00 in cash and cashes (cash out) a check for $1,500.00 on the same day, the single transaction totals $10,500 and therefore, a CTR is required?
08/11/2003
We have an affiliate that is an insurance agency. Although customers are given the choice to bring their own insurance policy, if they don't, we forceplace it with our affiliate. Even though we are not actually referring the customer, I am unsure if we should give the customer the Affiliated Business Arrangement Disclosure. My CO thinks that we don't have to, since there is no referral, but I have read a lot of conflicting articles on the matter. What is your opinion?
08/11/2003
We are purchasing a smaller bank. My questions is in regards to the purchsed bank credit card portfolio, both consumer and merchant. I am curious where I can get get guidance into the compliance requirements on the handling of the purchased bank's portfolio.
06/09/2003
I have been searching for a clear and current Financial Institution Record Retention schedule. Do you know of any resources for this material? I have been newly assigned to "revamping" our current retention schedule. Many of the problems I am running up against pertain to newer technologies used in banking, such as Internet Banking.
06/09/2003
Do you know where I can find a sample CRA statement?
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