09/22/2024
We have branch offices in three states. Do we need separate garnishment procedures for each state?
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?
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?
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?
09/15/2024
What does “A/G/O” mean when in a payee line? For example, “Susan Smith A/G/O Bandon Counts.”
09/15/2024
A husband and wife come to the bank. The wife has an account with us the husband does not. The wife withdraws $10,000 from her checking account. Then she and her husband cash three checks not drawn on us but made payable to both of them totaling $2,500. I know we will include this on the CTR under her Part I, but should he be listed on the CTR? He only benefited from the $2,500 but is that transaction tied with her for the CTR?
09/08/2024
We have an individual account that has been receiving recurring ACH debits monthly. The account owner died 6 years ago. The bank just found out about the death only days ago. No personal representatives have come forward or are known to contact. The most recent ACH debit was paid and overdrew the account. The account has now been overdrawn for 45 days.
Can we return the ACH debits that occurred after the date of death? Although the debits have been occurring for years, the bank just became aware of the death of the account owner.
09/01/2024
Is an email consent disclosure considered "written consent" for ChexSystems? I have a lender who would like to email the ChexSystems consent disclosure to account owners and use their reply to the email as proof of consent. Does this satisfy the requirement that the consent be in writing?
09/01/2024
We received a dispute yesterday for 51 transactions for a total of $529.33 from May and June - the customer stated on the dispute packet that she first became aware of the charges in January 2024, but they were small dollar amounts, so she wasn't worried. She never reached out to us until yesterday (6/27/24) to dispute the 51 transactions from the same merchant that she suspected of fraud in January.
Is the customer liable for the full amount since we could have prevented the 51 additional charges to post if she had reached out to us in January? Is that considered customer negligence?
08/25/2024
I need to reverse provisional credit but the customer does not have the funds in the amount I need to reverse, can I proceed with the reversal of the provisional credit, which will put the account in a negative balance ?
I understand we cannot charge any OD fees and will notify the customer we will honor checks, drafts, or similar instruments payable to third parties and preauthorized transfers from the consumer's account (without charge to the consumer as a result of an overdraft) for five business days after the notification. We must honor items as specified in the notice, but need honor only items that it would have paid if the provisionally credited funds had not been debited.