03/17/2008
Can you direct us to a government list regarding search requirements under 314a? The FDIC has requested that we include ACH debits and credits as well as bill pay payees. They also advised us that the sale of monetary instruments has no threshold, so all transactions are to be checked not just 3-10K.
01/07/2008
I am looking for some guidance on industry standards. Per the BSA Exam manual, we are doing some additional due diligence on customers we know now have ATMs. In several of these cases we obtained copies of the ATM contract and it appears our customer is responsible for filling the cash machine. When we further inquire about this, multiple customers do not have a contract with an armored car company; they say they are filling the cash machine with their own cash. We can confirm this activity as we do not cash checks for them in 20s for their cash machine (like we do another customer) and we see the ACH credits going into their account. My issue is, how do I further mitigate or document this? The risk with ATMs is that the customer is attempting to launder dirty money. When the customer tells me that they are filling the ATM with the excess money from their till, it could appear they are trying to launder money. If you have any ideas on how we can document this activity as an acceptable risk I would appreciate it.
10/07/2007
Use of the Category ?Other?
06/25/2007
I am wondering if anyone has any knowledge of what the generally-accepted definition of "substantially regular intervals" is in terms of preauthorized EFTs under Reg E - is it at least every 60 days as is mentioned in 205.10(a)(1)?
05/01/2007
The Federal Bureau of Investigation opened an investigation based upon information in SARs filed by banks indicating significant check kiting activity.
04/30/2007
What regulations should be considered as we write our Remote Capture policy (Check 21, Reg E, Reg CC, etc.)?
09/11/2006
We're being requested by the US Treasury to handle, over the telephone, amongst other things:* non-receipt of ACH credit claims, * request for account ownership info, and others that they want to give to us. We do not have to resolve the actual issue real-time over the phone but at a minimum, take in their claim/request. They're referring to the Social Security Act (Section 1441, Title 26, Title II the Railroad Retirement Act of 1974 and the Right to Financial Privacy Act (12 U.S.C. 3413 (K)) and saying that we're required to comply. Are you familiar with this and what are we required to do?
08/14/2006
I work for a federal agency that sends literally millions of deposits directly to bank accounts each month. Our policy states that in the event a beneficiary does not receive a direct deposit in his/her account, we must verify with the bank that the deposit was not received. With the financial privacy act in mind, can banks verify whether or not a deposit has been received if the depositor knows the owner of the account, the account number, the SSN of the account holder, the amount of deposit and the date it was deposited?
11/21/2005
I need resources to assist in writing a policy for ACH, Networking and End User computing. Do you know of any sites or resources available?
10/01/2005
The Treasury's Bureau of the Public Debt advises hurricane victims they can redeem EE and I savings bonds that are less than a year old presented for payment from September through the end of Novem