Most Popular Operations Content
Are we an ODFI, or not?
07/14/2024
We have come across this debate many times with Nacha rules whether or not we are considered an originating depository financial institution (ODFI). We do not allow our customers to originate ACH files such as payroll, etc. We do allow them to initiate WEB entries for A2A transfers from accounts that they are owners of in order to make loan payments here and transfer funds. Does this mean we are an ODFI?
Extending the maturity date when the home is owned
07/14/2024
We have a HELOC that is maturing 7/15/2024. Both borrowers are deceased. The son was paying the interest due each month. He does not qualify to put the loan in his name. We have agreed to give him a 90-day extension to either sell the home or get financing to payoff our loan. I have a copy of each of the borrowers' wills. Everything was bequeathed to the son and daughter equally. The daughter was named as the personal representative of the will and was authorized and empowered to sell, dispose of and convey all property, of every kind and character, which is owned at the time of death. My question is, who has to sign the loan extension documents? Is it the personalrepresentative of the estate?
Joint account withdrawals and CTR filing
07/07/2024
I have a CTR question. Husband writes a check to Wife for $10,000.00 and she cashes it. Husband then uses the ATM to withdraw $600.00 from his debit card. There is no way to know if both of them are benefiting from each transaction. Would a CTR be filed?
Closing a gullible customer's account
07/07/2024
Suppose that you have a customer that is 100% the victim of a scam. The transactions clearly show P2P withdrawals going to random people, the customer is purchasing gift cards at dollar stores and grocery stores and admits to sending this money to "a friend." The activity gets worse and worse every time you look at it, but the transactions are all authorized debit card purchases. Therefore, it is the customer's own money being spent, and the customer refuses to believe they are speaking with a scammer. Is this reason enough to close an account for suspicious activity? Is it a waste of resources for the account to be monitored?
Trust account exception
07/07/2024
What is an example of a trust exception?