02/04/2013
Is it still a requirement to illuminate a vault if it is visible from outside? If so, where can I find this as proof?
02/04/2013
I participated in a recent seminar where BOL Guru Dana Turner was the presenter. He mentioned that there might be a conflict of interest if the bank's Security Officer was also a director. I am in that position and I have discussed this with the Board/Executive Committee and was told today that they had talked with our bonding company and were told this was not an issue. What is the rational for ensuring that our Security Officer should be an employee, rather than a director?
01/28/2013
The Fed box on a note. For a car loan, can you only put the year of the car and maybe the make. Do you have to have the vin # there as well?
01/28/2013
We have a loan that has been charged off. The loan is secured by a property located in a flood zone. The bank is still accepting recovery payments from the borrower and has not released the interest in the collateral. The bank does not have any intention of foreclosing on the property, but does not want to release the interest. Is flood insurance required for the recovery account?
01/28/2013
BSA/AML Question: We have a customer who has sufficient CTR filings to consider filing a DOEP; however, they do sell ATVs, snowmobiles, and motorcycles. Are those items considered a motor vehicle and ineligible business for exemption?
01/21/2013
Can an assumed name be added to an existing account which CTRs are filed on? Or is it best to open a new account? My concern would be future CTRs would have assumed name which had not been on the former CTR filings.
01/14/2013
Does the following certification need to be included on signature cards for the State of Californai? I certify, in accordance with the IRS W-9 instructions provided by the Credit Union and under penalties of perjury, that the Social Security Number (SSN)/Taxpayer Identification Number (TIN) shown is my/the correct identification number and that I am NOT, unless designated below, subject to backup withholding because I have not been notified that I am subject to backup withholding as a result of a failure to report all dividends or interest, or because the IRS has notified me that I am no longer subject to backup withholding. I am not subject to backup withholding I am not a United States citizen or resident (complete W-8 form)/ Exempt
01/14/2013
If a customer deposits over $10,000.00 into a joint account, how do you fill out the new CTR if only one owner is present? Would you check the person conducting transaction on own behalf box for the owner present, making the deposit? And then check the person on whose behalf transaction was conducted box for the joint owner who was not present?
01/14/2013
Is the "Official Interpretations" section of Reg E subpart B Remittance Transfers part of the Reg or just someones interpretation? Section 1005.33(a)-5. i., ii., and iii. Procedures for Resolving Errors. This makes no sense to me to hold the sending bank accountable for something beyond their control. I would think an error such as this would fall under "Extraordinary Circumstances." I have to present this to our President and CFO so your answer on this would be greatly appreciated.
01/07/2013
When submitting a CTR for a business with a corporate address and a site-specific address, which one do we use?