08/01/2005
If a loan customer (either business or consumer) lists income on the application or financial statements that does not agree with submitted tax returns, does this trigger the need for us to file a SAR on the business/consumer?
07/18/2005
Our DDA statements state that if the customer does not dispute the information within 10 days of receiving it, it is considered correct. We have a customer that claims a girl friend forged his name to checks going back to January 2005. Are we obligated to reimburse him for this money?
07/04/2005
Some consumers believe that the images of checks are not as good as the checks themselves. What are the rules on this for proof of payment or prosecution of forgery?
07/01/2005
- Approximately 12 million CTRs are filed annually. FDIC, Supervisory Insights, June, 2004
07/01/2005
06/20/2005
If bankers have a policy not to ID existing customers: <ol><li>How then are they satisfying CIP? <li>Are they assuming the risk? <li>Or is there some other way to handle this? <ol>We were assuming the risk and made an assumption that we had previously identified our existing customers before the regulation was passed. With stepped up compliance, we are no longer comfortable accepting this risk, but cannot think of any other alternative than to ID our existing customers. We cannot seem to identify any workable alternatives. Do you have any suggestions
06/01/2005
The fear of criminal action being taken by the Department of Justice for Bank Secrecy Act violations has led to two principal consequences, according to William J.
05/02/2005
Can you provide some guidance regarding CTR Exempt Account Reviews? What is the time period expected to be covered for the annual and biennial review (i.e. 6, 9, 12 months) for suspicious activity and what supporting documentation is expected to be in the file (i.e., copies of monthly statements, deposit detail -cash in, checks, checks reviewed to determine if unusual for the business)?
05/02/2005
A SAR was filed and we have been contacted by the IRS for information regarding the filing. If the IRS Agent wants information relating to this individual on accounts that were not mentioned in the SAR or wants information that occurred before the SAR date or after the time period recorded in the SAR should we require a subpoena?
05/01/2005
(Note from Editor: When Check 21 becomes fully operative on October 28, 2004, the major part of the actual processing, clearing and posting of checks will not touch the branch office at all.