03/16/2009
Which supplier failures could cause significant impact to bank operations?
12/08/2008
If funds transferred from the vault for use during the day as well as funds remitted by the tellers are kept in a safe outside the main vault, is it a good practice for the supervisor to have sole custody of both keys of the safe? Secondly, if tellers have loose notes in their mallets at the end of the day (representing the float in their tills) which are not double counted by the supervisor, is it good practice for a bank to keep a duplicate of the key to the mallet which can be used in case of an absence of one of the tellers? Would this entail a risk of accountability in case of a cash shortage when the bank opens the teller's mallet in his or her absence?
09/22/2008
What position (head teller, loan officer, etc.) of the bank would be the best candidate for our BSA officer? Would it be our compliance officer?
09/15/2008
We are having a debate on how the Phase II exemptions work. I thought when you exempted a phase II customer, they could only be exempt for deposits or payroll withdrawals. Another person here thinks if it is a Phase II customer, they are automatically exempt for deposit and withdrawals and that there is no distinction or specification about what types of transactions are exempt.
07/14/2008
I'm a former assistant Compliance Officer now working in our Operations Department. I have a discussion going with the new assistant Compliance Officer regarding a BSA question. We had a customer deposit $10,000 in cash in a personal account, then purchase an Cashier's check for $7,500 for a total of $17,500 in cash. I was always under the impression a CTR overrides an MIL, but the new assistant is saying that we need to complete a CTR and a MIL. I'm saying we only need to complete a CTR. Who is correct? Where is this addressed in the regulation?
03/31/2008
I plan to include a recommendation in my annual report to change the current reporting structure for the Security Officer. Presently, I report to the VP of Retail Operations. I am seeking references to cite that advise the bank security reporting structure should be in other areas such a finance, risk, administration, but not through retail because of the apparent potential for downward influences and the need for independence.
12/03/2007
Who should be on the Security Committee?
10/08/2007
How long are we required to keep checks and deposits presented over the counter? We are sending and receiving images electronically.
10/08/2007
Are banks required to search the OFAC lists on domestic banks when wiring funds?
09/25/2006
I have been posed with a record retention question regarding documentation that both a CIP and OFAC was completed on. These are internal procedures that our operations department have set up themselves and is above and beyond what I can find the regulation actually stating. Is there any guideline as to how long we need to keep such extra documentation?