05/01/2007
In early 2006, a U.S. Attorney?s Office secured guilty pleas from two businesses for evading Bank Secrecy Act (BSA) reporting requirements by structuring deposits.
04/16/2007
For an account which electronic fund transfers can be made, may the bank send a notice each time with the date, amount, source and account number and not the other information that would be on the monthly statement as opening and closing balance in place of a periodic statement for each monthly cycle in which an electronic fund transfer has occurred? In particular, on a savings account that is normally sent a quarterly statement when no EFT activity has occurred, will the notice mentioned above suffice for a direct deposit to the account in place of the monthly statement?
02/05/2007
The IRS Publication on Form 1098 is very vague. Should the bank be sending out a 1098 for mortgage interest on rental property that is financed? John Doe financed a rent house and now rents to Frank Doe. Does the bank need to send John Doe the interest paid on a 1098 form at year end?
01/15/2007
Can we list "retired" in the occupation field when filling out a CTR? Do we really need to know what business or trade the individual is retired from?
09/11/2006
We need to open up a donation account for a young boy who has cancer. Would the best way to do that be to put the boy on as primary owner with his social security number and add whomever they want to act as the person handling the account as joint or would they just be authorized signers? I am assuming that most of the checks would be made out to the "boys name cancer fund" OR would this type of account need it's own EIN #?
09/04/2006
We are going to start check imaging rather than sending checks to our customers. What is the best way for us to inform our customer about imaging? We have an older customer base and want to make it as easy as possible for them to make the transition. Would a letter from the bank President be sufficient, or are there any statement stuffers available that explain imaging?
09/04/2006
I have a new account for a Non-Profit Unincorporated Association that is wanting to use the TIN of their For-Profit Sponsor. Shouldn't they be applying for their own TIN?
08/28/2006
Our bank does servicing of "Contracts for Deed." This is where a buyer and seller enter into a contract for deed between themselves, the bank receives the payment from the buyer and disburses it to the seller. My question is, are we required to verify both buyers and sellers for CIP?
08/14/2006
We recently received notification from an IRS agent requesting the back-up information on a depositor on whom we filed two SARs. Should a subpoena be received before we release the materials?
07/17/2006
Can an IRA CD be used as collateral for a loan?