08/14/2006
In reference to the question below, would you also be required to report a loan to a mortgage company that is not affiliated with any bank? Ex Officer Reporting Loans from other Banks by Randy Carey, BOL GuruQuestion: Regarding Regulation O Section 215.9, relating to Executive Officer reporting loans from other "banks." Does this definition of Banks mean only members of the Federal Reserve? We are regulated by OCC and I looked in their Insider Activities handbook, but it only states "215.9 - Reports by Executive Officers "Executive officers" must provide a written report to the board of directors within 10 days of becoming indebted to any bank if the aggregate amount of the indebtedness exceeds $100,000 (or the greater of 2.5 percent of the bank's capital and surplus or $25,000). The report shall state the lender's name, the date and the amount, security, and purpose for each extension of credit."Answer: The term "bank" alone is not defined within the regulation. I would interpret it to be defined very broadly and would include any type of bank, whether a member bank or not. First published on BankersOnline.com 1/30/06
04/24/2006
Does the Bank Secrecy Officer have to be a senior level officer at the bank? What section of the regulation covers this?
01/30/2006
Regarding Regulation O Section 215.9, relating to Executive Officer reporting loans from other "Banks." Does this definition of Banks mean only members of the Federal Reserve? We are regulated by OCC and I looked in their Insider Activities handbook, but it only states 215.9 Reports by Executive Officers "Executive officers must provide a written report to the board of directors within 10 days of becoming indebted to any bank if the aggregate amount of the indebtedness exceeds $100,000 (or the greater of 2.5 percent of the bank's capital and surplus or $25,000). The report shall state the lender's name, the date and the amount, security, and purpose for each extension of credit."
12/05/2005
Is there an annual IT certification the board must make for Graham Leach Bliley compliance?
09/01/2005
07/04/2005
When opening credit cards for joint cardholders, the primary account holder's credit bureau is pulled for underwriting purposes as well as to verify the identifying information. Identifying information is obtained from the secondary, but no credit bureau is pulled unless it is needed for underwriting purposes. What are the verification requirements on the secondary cardholder? Does the bureau need to be pulled? Can another source of public information be used? Is it even necessary to verify the second cardholder's identifying information?
07/01/2005
On July 30, 2002 the Sarbanes-Oxley Act (SOX) was signed into law.
07/01/2005
I had a call today from a reporter for a major U.S. newspaper. He wanted to know if there was nationwide activity on counterfeit official checks.
06/01/2005
Question: I know we are required to have Robbery training once a year. Is that calendar year? Or is it every 12 months?
05/16/2005
If a person is a signer on a business account, are we required to get their Social Security number for CIP or any other reason?