05/20/2013
Applicant wants to take equity out of their primary residence at 123 Main Street in order to purchase a secondary residence at 456 Washington Street, using the Main Street as Collateral. Which property should we report on the HMDA LAR?
05/13/2013
We submitted a breach of warranty claim regarding a forged endorsement on a check for $169,338.01. We submitted an indemnified copy of the check along with the signed and notarized affidavit of forgery. We are located in New Jersey. How long does the depository bank have to respond? They say that they have 90 days.
04/29/2013
Do you have to run OFAC on non-customers presenting VISA debit cards for payment of social security or tax refunds?
04/22/2013
Can a bank accept a stop payment from a online banking account without a signature? Will the printed request be sufficient and hold up in court?
04/15/2013
When filing a SAR for insider abuse, should the narrative contain any admissions, denials or conversations HR had with the employee in regards to the alleged activity? Is it required to include that information?
04/15/2013
The new E-Filing form FinCEN CTR form 112 doesn't require us to enter any option in field number 39 (rssd #) should we be entering this information anyway? and if so, do we have to go back and redo all the prior CTRs or wait for them to be returned?
04/15/2013
During my most recent BSA/AML report to the board, there was discussion regarding the number of cases/investigations we conduct versus the number of those that actually result in a SAR filing. The board asked if I could compare our percentage of filings with other banks. I'm not certain that there is a good way to do this comparison due to the many variables in each bank and how they address those variables. Do you have any advice how to properly address the question?
04/15/2013
When setting up businesses for online banking, ACH, and remote deposit capture, does the bank maintain control over users of the business or do they set up an administrator for the business for them to maintain?
04/08/2013
We have a main office and five branches. We have always used our main office address for CTR filings (and recently the RSSD for the main office). I became aware today that each branch has its own RSSD number (thanks to your BOL Daily Briefing)Should we start using the individual branch address and unique RSSD number, based on where the transaction took place for CTR filing? What if it has multiple transactions and multiple locations?
04/08/2013
We are reviewing our emergency evacuation drills and attempting to reinforce the need to be ready for the unexpected without creating panic in the branches. Any best practices suggestions on how to accomplish this?