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May 27, 2015
Compliance Management – Phase 1, your Program and Training
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Integrated Disclosures 101
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50 Key Considerations for Integrated Disclosure Rules Readiness
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Deborah Crawford

Topic Options
#1599147 - 09/01/11 11:50 AM True or False
Laketime Offline
Platinum Poster

Registered: 08/23/02
Posts: 539

Employee dischonesty from a 4-year employee of the bank. Small amount stolen approximately $100. Employee admitted taking the money to cover day care expenses (long story, single mother, apologized, was going to replce it, was desperate, she cried, we cried, etc., etc.) and has resigned from the bank. Her brother came into the bank and made full restitution. After a very lengthy search we have found no additional monies missing.

I realize there is a an SAR in this situation.
I am looking to see if there is some FDIC reporting form. I believe years ago there was, but I do not think there is currently a reporting obligation on these type of losses (I suppose the SAR is sufficient as they (the FDIC) have access to that data).

But my real question is as follows:

I have had a member of management ask me if we are absolutely obligated to report this person to our bonding company? (I know philosophically we should to protect the next financial institution), but I want to know if it is absolutely required as I can't see anything in the 35-page fidelity bond.

T or False?

Are we absolutely required to report the person the fidelity bond carrier? (Thus I presume she would become "unbondable")

Thanks for any responses.

Security - Public
#1599357 - 09/01/11 03:49 PM Re: True or False [Re: Laketime]
FraudFinder Offline
New Poster

Registered: 08/23/11
Posts: 11
Not sure if this answers your question but Section 19 speaks a lot about acts of dishonesty against an insured institution which I assume you are. The de minimis provisions are something she'd need to be measured against regarding bonding etc.

So this is my round about way of saying even if you weren't required she'd probably be required to state it on her application at the next bank and by omitting it would be a dishonest act and she be better off with full disclosure.

So if someone were say trying to help her out of a one time big error in judgment the best thing would be to advise her to disclose it and then use the de minimis portion of section 19 to proof her ability to get bonded.

Or maybe I am reading it all wrong and just served to confuse you more if that is the case my apologies. smile

#1599565 - 09/02/11 10:26 AM Re: True or False [Re: FraudFinder]
Laketime Offline
Platinum Poster

Registered: 08/23/02
Posts: 539

Thank you for your response. Just to clarify, Section 19 refers to what document?

#1599627 - 09/02/11 11:52 AM Re: True or False [Re: Laketime]
califgirl Offline
Diamond Poster

Registered: 03/04/02
Posts: 2325
Loc: The O.C., California
I can explain it to you. I can't understand it for you.


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