12/24/2017
What can we use to try to help educate customers about warning signs of identity theft?
12/17/2017
In the event someone attempted identity theft at our bank, but we caught it and therefore didn’t suffer a loss, do we not have to file a SAR?
04/01/2013
A question about CTR exemptions. We have a customer who owns a bowling alley. He has the bowling lanes, the pro shop, the snack bar and a children's party room organized as four separate businesses, each with its own tax ID number. Invariably, deposits are made for all the businesses at the same time, so they are aggregated and reported on a CTR when the cash amounts exceed the 10K threshold as the same individual makes all the deposits. Is it possible to exempt these businesses even though individually none of them ever exceeds the 10K reporting threshold? I assume that we would have to file a separate exemption form for each business.
10/22/2012
Can beneficiary be added to a business account that is set up as a sole proprietorship and using the individuals social security number on the account?
09/03/2012
We have a potential new customer who does business as a scrap dealer (appliances etc.). He receives checks made out to the name of his business. Does he need to have an account titled with the business name or can the checks be deposited into an account in his name, since it is a sole proprietorship and does not have a federal tax ID for the business? How should sole owner accounts be set up?
01/09/2012
A local college (bank customer) gives "scholarship" checks to students to use as they want. We never know when they will be issued or for how much, but the total is quite large. We do not keep that much on hand to cash these checks. An agreement with the college is that we will not cash these "on-us" checks for more than $1000. Can we refuse to cash on-us checks?
12/05/2011
Is there any regulation that requires obtaining/retaining a copy of a social security number and drivers license for any and all checks cashed for a non-customer, whether it is an on-us check or a check from a non-customer to an existing bank customer? We do understand the need to pull OFAC on all transactions that involve a non-customer no matter the amount of the check. It is very time consuming to make copies of IDs and the checks. Are examiners going to the extreme? If we check identification, it seems that with the OFAC that should suffice. Are all banks required to do this now?
06/27/2011
BSA/CTR Filings Section B (item B mail deposit or shipment). We cannot find an description of what that would include (shipment). Can you please help us?
03/07/2011
We recently had a member come in and pay off her auto loan in cash, $10,500. She however had a non member with her who had the cash in her possession and handed it to the teller. When asked to produce ID for the large sum of cash she said that she did not want to. She would be the conductor but her identity is unknown. How should the CTR be filled out?
02/28/2011
I need to file a SAR on a customer whose account was opened before the PATRIOT ACT... which means that there is no DL information on the customer’s account. Short of calling the customer, I have no way of getting this information. Can I complete the SAR and leave the ID information section blank or is that a "no-no"?