09/24/2007
I am looking for the rules and Regs on annual security reporting to the board of directors. Where can I find this information?
08/13/2007
We have had examiners question different banks in our holding company as to whether we have an executive officer kidnap policy. We don't and I have not been able to find any guidance or sample policies. Can you direct me to resources to assist?
07/09/2007
We are having a misunderstanding at my financial institution about the USA PATRIOT Act. We were first opening corporate accounts and gathering identification documentation and social security numbers on all the signers on corporate accounts. We were then instructed that it was unnecessary to obtain this information on the signers. Then about a year later we were instructed that the USA PATRIOT Act does require us to get this information. Does BSA or the PATRIOT Act require financial institutions to get ID for signers on corporate accounts as of 2007? If it does not, where can I find this information?
06/11/2007
During our last BSA exam, it was recommended that we include procedures for considering closing an account due to suspicious activity. Do you have any suggestions for this recommendation?
05/21/2007
I have been newly appointed to a bank Board of Directors and have little banking knowledge. I have been approached by one of our tellers with a concern about CTRs. It seems that on a regular basis (couple times a month) a customer comes into the bank with two checks around $6500.00 each and has them cashed. One is in his name the other is in his father’s name. Each time he is alone and walks out of the bank with around $13,500.00 cash. My teller is afraid that this is a BSA violation. Is this a violation? Would this at least warrant a Suspicious Activity Report?
01/02/2007
If an employee at a bank was caught kiting and not terminated or reprimanded in any way, who can I report this to?
10/09/2006
What are the bank policies that need board approval and how frequently?
10/02/2006
Should the BSA Officer report directly to the board of directors?
09/18/2006
We are a little confused on the latest requirements regarding getting a second ID for existing customers. If an existing customer has a CD with us and comes in to change the term, are we required to get two forms of ID? (Our new accounts department is getting overwhelmed.)
09/11/2006
Is it now a requirement or just a strong recommendation that members of the Board of Directors receive training on BSA?