04/09/2012
During the Top Gun 1st day session presentation from Tom Fleming @ FinCEN, the subject was brought up about bank customers who individually contract with armored car services instead of using a bank contracted service are required to provide conductor information for the CTR form. We have two customers who use a national armored car service which also happens to be the same service that the bank has contracted with. When the monies are delivered to the bank for these two individual customers by the armored car driver, they are refusing to provide their personal information as the conductor. We circled back around to the national armored car representative for our bank and they are stating that they don't feel that the armored car driver should have to provide their personal information as they work for the armored car company and not the individual customer who is receiving credit. So the question is, do we refuse to accept further deposits from a long time customer because of this issue? Has FinCEN provided any further communication regarding this situation? I would imagine we are not unique to this situation, however, as I stated above, these two customers are using a nationally known armored car service, not a company that is not well established in this type of service. Any and all information would be greatly appreciated.
10/02/2006
In the past, we sent mortgage loan closing documents to the title company via the internet. We stopped this practice because we feel that without having a secured e-mail line, and without encrypting the data, we would be in violation of GLB. Same with sending our Good Faith Estimates, or other disclosures. We stopped sending via e-mail to customers because of GLB issues. Are we correct in that it would be a violation of GLB to send non-public financial information electronically over a non-secure line?
08/14/2006
In the past, we sent mortgage loan closing documents to the title company via the internet. We stopped this practice because we feel that without having a secured e-mail line, and without encrypting the data, we would be in violation of GLB. Same with sending our Good Faith Estimates, or other disclosures. We stopped sending via e-mail to customers because of GLB issues. Are we correct in that it would be a violation of GLB to send non-public financial information electronically over a non-secure line?
09/22/2003
Can you tell me what the standard industry practice is with regard to microfilming daily work in the branches? What are the risks of not filming prior to getting the work to the item processing center? How does this practice fit with disaster recovery procedures?
08/18/2003
In the past, we sent mortgage loan closing documents to the title company via the internet. We stopped this practice because we feel that without having a secured e-mail line, and without encrypting the data, we would be in violation of GLB. Same with sending our Good Faith Estimates, or other disclosures. We stopped sending via e-mail to customers because of GLB issues. Are we correct in that it would be a violation of GLB to send non-public financial information electronically over a non-secure line?
08/18/2003
The term "e-banking" is what I need help with. What is the definition of "e-banking"? Our bank offers on-line banking, however, accounts cannot be opened on line, only transactions. The paperwork is done either in-person or by mail. Is this true "e-banking"?
02/17/2003
An issue has come up a couple times in the recent past: Our customers are sending emails directly to our employees, especially our commercial customers. The emails are not encrypted or password protected and they often contain non-public information - loan requests, updates on rent rolls, financial information on their company. Our customers want us to communicate in email form. We offer email that is encrypted via our Internet banking product. However, the lenders are telling me that their customers will not go through the inconvenience of logging in to Internet banking to communicate. Our Privacy Policy does extend beyond the minimum requirements of GLB; we opted to include commercial customers under the privacy blanket. Our E:Banking Policy does not address communication of non public information via email (incoming or outgoing). Does anyone have a practical solution to this growing concern?
02/17/2003
We want to expand on to the Internet with our Branch office and I'm not sure what we have to do to expand into other states. We currently use Caylx Point. Can you offer a suggestion or two? We only use Email now, but later plan to have a Web site!
02/17/2003
Do you know where to find information on the number of banks that outsource their core bank processing functions? Also, do you know if there is an estimate of the size of the total outsourcing industry in terms of revenue? Thanks!
02/17/2003
Our financial institution started imaging checks in November 2001 and as a result the original documents (checks) are no longer being sent back to our customers. My question is, "How long should the original documents be kept?" We checked with the Cincinnati Federal Reserve and they keep the original documents for 45-days and then destroy. Are we required under regulation to keep original documents for a certain period of time?
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