06/23/2008
Do our Systems Administration IT guys and human resource people need to be trained on BSA? I am the new BSA Officer for a Savings Bank and the above have had no BSA training.
05/05/2008
Can you tell me if signage for the USA Patriot ACT must me at a certain size, color, etc and must it be posted at teller window's and at new accounts desks, or can it simply be posted in a main area of the branch?
03/31/2008
An issue has arisen at my bank concerning the need for a signatory on a homeowners association account to submit his social security number. My bank's BSA Officer believes that he must do so. I am not so sure. This individual has no personal accounts with our bank, but is listed as a signatory on two accounts dealing with homeowner's associations. The person in question refuses to give his social security number. How are HOAs classified for purposes of the USA Patriot Act? It's my understanding that the HOA is the owner of the account. I know that the signatory situation was in the proposed rules, but not the final ones. I would appreciate it if someone could provide me with some guidance.
03/12/2008
By Staff of the Financial Industry Regulatory Authority and the Securities and Exchange Commission22
10/19/2007
John S. Burnett, BOL Guru
08/20/2007
A customer came in and opened a checking account for her disabled uncle. She is the uncle's legal custodian. Due to the USA Patriot Act (CIP) do we need to get ID from the uncle? How should the account be titled? Is the uncle the beneficiary?
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?
08/14/2006
My understanding is that the USA PATRIOT Act forbids the negotiation of government checks by anyone other than the payee or payees. Do you know where I can find this in print as I have an irate customer that wants me to "prove it" when I told him I was unable to accept a government check made payable to someone else because of the second endorsement required.
07/03/2006
If a person is on a title as "other owner only" and they are not co-signer on the loan and do not have an account with us (nor are they opening an account) where do they fall under the USA PATRIOT Act? Do we have to get ID on them and verify it?
11/21/2005
Is the 314a request the same thing as the OFAC list? I was told they were 2 separate things and I was also told that the 314a requests are the new names that will be included on the OFAC list. Could you please tell me which one is correct?