11/16/2009
Our bank is second in a participation loan. Do we have to obtain identification and CIPs for the guarantors?
10/26/2009
Is there a certification course available for financial institution security officers?
10/19/2009
I work in bank fraud cases. We have a case management system in which we input all of our fraud cases (forgeries, counterfeit checks, unauthorized check card trans,etc...). We are trying to make a determination as to the difference between "recovery" and "loss avoidance" when it comes to bank fraud. Could you please help with a clear understanding on what determines in which category an item would fall?
09/21/2009
In determining whether CIP info is required on signers/trustees for a loan on a church, how is a church classified that is operating as a non-profit organization? A church that was incorporated could be classified as a corporation, acting as a legal person. However, civic clubs, etc., are considered entities that are not legal persons, which would require CIP for all signers. Where do non-profit organizations fall in classification?
05/18/2009
How can the bank optimize its vendor risk management efforts?
12/15/2008
What are regulators currently looking for in business continuity plan testing?
10/20/2008
Are there restrictions on a customer putting several hundred thousand dollars in his or her safe deposit box?
08/04/2008
Question: What should we do to comply with Red Flags risk assessment requirements?
06/02/2008
When a bank has an indirect lending relationship with a car dealer, then how does it go about complying with enhanced due diligence, CIP, etc.?
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.