Vendor Guru Q&A - Operations

Latest Operations - Deposit Topics

No opt-in, no overdraft fee

11/25/2018

Can we charge an overdraft fee for a one-time debit card transaction that overdraws an account of a customer who has not opted-in if there were sufficient funds at the time of authorization but not at the time the transaction posts?

Deadline for ACH returns

11/25/2018

Does the "midnight deadline" apply to ACH items?

Back filing a CTR? Who gives permission?

11/11/2018

If we fail to file a CTR, do we have to contact FinCEN?

BSA Training for the Board?

11/04/2018

How often do I need to train my Board?

How far is enough? To know our customer?

10/28/2018

Do we really need to ask all these questions at the new account opening?

BSA Risk Assessment length? 10 pages?20 pages? More?

10/21/2018

How long does my risk assessment have to be?

Is the FFIEC BSA AML Exam manual up to date?

10/14/2018

Does the BSA Exam Manual and the BSA regulation match?

Reg CC Hold-Cashier's Check & Personal Check

09/16/2018

Please advise on the following scenario: Customer deposits a $4000 cashier's check with a $5000 personal check (total deposit $9000). This is not a new account and we have no reason according to Reg CC so be able to hold the cahier's check. The teller wishes to place a case by case hold on the remaining $5000 of the deposit. Per Reg CC would she only be able to place a hold for $4800, or could she hold the whole $5000 for two days because she has already released the $4000 due to the cashier's check?

Deposit Made By Individual Not on Acct- CIP Info?

07/08/2018

If an individual NOT on an account is making only a deposit, are we required to gather CIP information on them?

You don’t have to investigate all Reg E claims.

07/01/2018

Why do we have to investigate all Reg E EFT claims?

Technical 314a Fields

12/03/2023

Does the FinCEN 314a list have specified field definitions? i.e., field lengths.

One Sig Card for All Accounts

12/03/2023

Is it required to have a new signature card for each new account under an existing a person's CIF? If not, is there an example of a CIF card just for the signatures?

Data inconsistencies and payment channels

12/03/2023

How do aging payment solutions lead to data inconsistencies and processing issues across your deposit channels?

Do we have to take a POA?

11/26/2023

Do we have to accept a POA?

Unauthorized or Chargeback?

11/26/2023

A cardholder let's, lets call him Grandson A, use grandma's card to make a Temu purchase. Her other grandson, B, never had authorization to use the card. Grandma begins to get unauthorized or unfamiliar charges from Google and CashApp on her account. She states she thinks Grandson B took her card out of her purse, made the transactions, and placed the card back. Are we able to file a chargeback on the charges based off the her assumption that Grandson B took the card info?

Latest Operations - Deposit Topics

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