10/03/2011
Are we legally required to list the complete account number on any bank mailing (overdraft notices, statements or any correspondence to a customer)? Are we allowed to suspend the first 5 of our 10 digits?
11/29/2010
We are deciding whether or not to provide e-statements on our internet site. What are the required disclosures needed to provide this service? I understand that the customer can choose whether or not to receive his/her statement electronically.
04/06/2009
What disclosures need to be posted on our website for customers to receive their statements electronically and be in compliance with E-SIGN?
03/30/2009
Does the Federal Privacy Act prohibit a bank from verifying funds for another bank if a customer presents a check drawn on a customer's account?
03/23/2009
Can someone please explain what “push” and “pull” mean in regards to e-banking?
11/24/2008
What formats are available to assess risk?
11/24/2008
We had a customer come in to make a withdrawal on a savings account. He stated the balance of the account was about $6,000, but our records show he has had an average balance of only $1,300. Later in the day he was able to produce what he claims to be three 2007 statements mailed to him from us. These statements do not look anything like what we produce and had many errors with interest, balances, dates, statement periods and logos. It also does not match the activity we show for 2007 and appears to us to be badly produced fraudulent statements. We are currently pulling all statements since he opened the account to see if we can find any errors in the activity. Since 12/07 his account has been on our do not mail list because of a wrong address. Should we have him sign a statement regarding the statements he produced for us stating they were received in the mail for future reference if they are proved to be fraudulent? I am following up on the research of the account to verify, but it appears that he is attempting to commit fraud since his produced statements do not match our statements for the same period.
09/22/2008
How long does a commercial business have to claim a forged signature?
01/07/2008
I am looking for some guidance on industry standards. Per the BSA Exam manual, we are doing some additional due diligence on customers we know now have ATMs. In several of these cases we obtained copies of the ATM contract and it appears our customer is responsible for filling the cash machine. When we further inquire about this, multiple customers do not have a contract with an armored car company; they say they are filling the cash machine with their own cash. We can confirm this activity as we do not cash checks for them in 20s for their cash machine (like we do another customer) and we see the ACH credits going into their account. My issue is, how do I further mitigate or document this? The risk with ATMs is that the customer is attempting to launder dirty money. When the customer tells me that they are filling the ATM with the excess money from their till, it could appear they are trying to launder money. If you have any ideas on how we can document this activity as an acceptable risk I would appreciate it.
04/16/2007
For an account which electronic fund transfers can be made, may the bank send a notice each time with the date, amount, source and account number and not the other information that would be on the monthly statement as opening and closing balance in place of a periodic statement for each monthly cycle in which an electronic fund transfer has occurred? In particular, on a savings account that is normally sent a quarterly statement when no EFT activity has occurred, will the notice mentioned above suffice for a direct deposit to the account in place of the monthly statement?
