07/09/2007
We are having a misunderstanding at my financial institution about the USA PATRIOT Act. We were first opening corporate accounts and gathering identification documentation and social security numbers on all the signers on corporate accounts. We were then instructed that it was unnecessary to obtain this information on the signers. Then about a year later we were instructed that the USA PATRIOT Act does require us to get this information. Does BSA or the PATRIOT Act require financial institutions to get ID for signers on corporate accounts as of 2007? If it does not, where can I find this information?
05/21/2007
I have been newly appointed to a bank Board of Directors and have little banking knowledge. I have been approached by one of our tellers with a concern about CTRs. It seems that on a regular basis (couple times a month) a customer comes into the bank with two checks around $6500.00 each and has them cashed. One is in his name the other is in his father’s name. Each time he is alone and walks out of the bank with around $13,500.00 cash. My teller is afraid that this is a BSA violation. Is this a violation? Would this at least warrant a Suspicious Activity Report?
03/26/2007
We have a BSA Program that contains both our policies and procedures. They are clearly identified within the Program, for example, CTR Policy and CTR Procedure. When we make a change to one of the procedures does this change need to go to the Board? It is my understanding that only policy changes are required but I am being questioned due to the fact they are kept together in a Program. Again, they are clearly labeled in the Program as to what is a policy and what is a procedure.
01/02/2007
Our e-newsletter program is brand new to us. If we provide a link to an external site that is not co-branded with our bank, are we required to have a speed bump? If so, what is the bare minimum we need to say? The reason I am asking is that we have a speed bump in place on our web site and it is quite lengthy. In this instance, if I were to add the speed bump, it actually has more content in it than our e-newsletter. I do receive e-newsletters from other banks and they do not have speed bumps. Since this area is new to us, I want to have policies in effect as we go forward.
11/20/2006
I attended a tele-seminar on 9/11/06 with Jack Holzknecht about Red Flag Guidelines; We just had an audit and we received a write up for not having any formal procedures in place to ensure identity of a customer requesting credit if a fraud alert appears on the customer's credit report. The recommendation read, "To mitigate fraud risk and ensure the proper identity, formal procedures should be created and implemented. Procedures may include additional steps for identification, additional security questions, as well as additional documentation to evidence of proof." If the Red Flag Guidelines are not finalized yet, how can we still get written up for it? Should the recommended policies be in place already even though there has been no Final Rule released?
10/09/2006
What are the bank policies that need board approval and how frequently?
10/02/2006
Should the BSA Officer report directly to the board of directors?
10/02/2006
We feel that our network is very secure against attacks that originate on the Internet. Are there other areas about which we should be concerned?
09/11/2006
Do new employees need to have robbery and BSA training within a certain amount of time from their date of hire?
09/11/2006
Is it now a requirement or just a strong recommendation that members of the Board of Directors receive training on BSA?