Most Popular Operations Content
SAFER Act vs SAFE Act
09/22/2024
I’m so confused! I keep hearing about the “SAFER Banking Act”. How is that different from the “SAFE Act” from several years ago? Is it being updated?
Procedures for multi-state branch networks
09/22/2024
We have branch offices in three states. Do we need separate garnishment procedures for each state?
3 items for Reg E liability
09/22/2024
A customer had a charge out of his account six months ago. That’s old and means he has unlimited liability so we don’t have to investigate it. Is that right?
Closing a gullible customer's account
09/22/2024
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?
Are we an ODFI, or not?
09/15/2024
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?