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denotes Guru Question & Answer.

Banking Related Court Cases -- See Court Cases

Bank Bribery Act
Accepting Gifts from Bank Customers
Customer Gift Giving
Accepting Gifts and the Bank Bribery Act
Can You Be Bought?


Bank Holding Company Act
Does Exemption Apply to All Banks Under the BHC?
Reg O - Bancshares as Collateral
Incentives and the Anti-tying Prohibitions
Bank Holding Company Act
Requiring Credit Life Insurance
Anti-Tying Requirements Defined
Consumer Protection Insurance Rules: What You Need to Know
A Discount on a Loan for Getting Credit Life Insurance


Bank Hours/Days
FRB Rule on Inclement Weather Closing
Changing Business Hours - Post Advance Notice?
Notify Regulator of Cut Off Time Change?
Only Drive-Thru Open Saturday - A Banking Day?
ATM Deposits – Next Day Availability?
Holding Checks - Member Notification
Reg CC - Saturday a Banking Day?
Loan Docs Mailed - Extending ROR Period
Reg E Error - Counting the Days
Rules on Banks Closing Due to Inclement Weather
Change in Branch Bank's Operating Hours
Saturday - Right of Rescission
Reg CC - Saturday Deposit of US Treasury Check
Posting Holiday Closing Signs
Number of Consecutive Business Days a FI Can Close
Closing a Branch Early, Notice Requirements
Return items for closed branches
RESPA Disclosures on Saturday
"We've Stepped Out -- Back in an Hour"
Notice Requirement to Eliminate Saturday Banking
Closing Branch to Repave Parking Lot
Are Billing Dispute Days Calendar or Business Days?
Guidance on Branch Operations Hours Requested
Work Hours
Changing Banking Hours
Extended Hours For The Safe Deposit Area
Full Service Banking On Sunday?


Bank Protection Act
Bank Protection Act - File Annual Report to FDIC?
Non-Bank Tenant Security Training
One Person at the Branch
Reason for the Bank Protection Act
Height Markers
Preparing Your Annual Security Program Report
State Bank - Federal Law Enforcement
New Emphasis on BPA by Examiners?
Overflowing Safe Deposit Function
Required Privacy Training
Recommended Initial Training
Monthly security meeting topics
Facility Requirements -- Bank Protection Act
Tracking Bait Money
Bank Liability for Employee Parking & Safety
Bait Money
Bank Security Requirements
Board of Directors Liability
Definition of "Tamper-Resistant Lock"
10 Potentially Catastrophic Mistakes During Bank Robberies
Alternatives to Bait Money/Bill Traps
Teller Safety Issues
Written Security Program Required
Bank Protection Act Building Security Requirements
Bank Protection Act Information
Audit Program For The Bank Protection Act
Bank Protection Act
MORE ON TAMPER-RESISTANT LOCKS
Question & Answer
What In The World Is A Tamper-Resistant Lock?
It's Working!…Or Is It?!
Minimum Security Final Rules


Bankruptcy
Hold Car Title as Collateral Against Charge Off
Removing Bankrupt Corp Account Signer
Securing Debt Payment
Avoiding Bankruptcy
Bank Employee Hiring Prohibited by Bankruptcy?
Loan Collection of Customer Filing for Bankruptcy
Denied Opening a Savings Account
Loan Declined Due to Customer Filing Bankruptcy
Bankruptcy - Re-scheduling Loan to Current Status
Denying Credit Based on Past Bankruptcy
Should This FCRA Notice be Sent to Bankrupts?
Procedures for bankruptcies
May We Deny a New Account?
Maintaining Bank-Paid Insurance Premiums
Disclosing Seller's Impending Bankruptcy to Buyer
Reaffirmation in Chapter 7
Bankruptcy: Ten Questions Every Bankers Should Ask at a 341 Hearing
Bankruptcy: Can we hot card a debit card?
Loans, Collateral, & Bankruptcy
Bankruptcy Discharged Debt: $0 on credit report?
Advance To Debtor After Guarantor's Bankruptcy Upheld
Bankruptcy & Collecting Late Fees
Disqualifying Loans Based On Prior Bankruptcy
Automatic Stay on Chapter 7
Advance To Debtor After Guarantor's Bankruptcy Upheld
Predicting Bankruptcies


Bank Secrecy Act
Bank Secrecy Regulation
MSBs and the BSA
CTR - Account Cash Withdrawal
SAR Filing Methods
Foreign Currency Purchase
Noncustomer Refuses to Provide SSN
OFAC & Purchase of Cashier’s Checks
CTR on Returned Stolen Money?
FinCEN Initiatives
CTR Reporting – Customer Query
Negotiable Instrument Log Entry
About CTR Exemptions and the BSA
CTR Filing - US Mint Coins
Deposits on Behalf of Exempt & Non-exempt Customer
SAR – Work at Home Scam
BSA Training Schedule
Commercial Loan - SAR Filing
BSA Monitoring
CTR on an Attorney Escrow Account
CTR – Cash Back on a CD
CTR exemption – Listed or Non-listed Business?
How to Implement Risk-Based OFAC Monitoring Practices
BSA – Is Savings Bond a Monetary Instrument?
BSA Officer Certification & Independent Gatekeeper
CTR Reporting – IOLTA Accounts
No Monetary Loss – SAR on Check Kiter?
CTR Completion Confusion
Stripping Down a Massive BSA Policy/Program
Payment & Withdrawals - Monetary Instrument Log
BSA/AML Risk Assessment
CTR on Bank Courier Service
CTR - Attorney State Bar Client Trust Account
Amending BSA Policy
CTR on a Local School
New CTR Exemptions?
Outgoing Wire Transfer - Physical Address Required
CTRS on Totten Trusts & TXUTMA Accounts
Representative Payee - CTR Filing
CTR on Closing Cost Down Payment
Transitioning from Magnetic Filing to Electronic Filing
CTR Filing – Joint Spousal Account
FINCEN Brochure on Structuring
Form to Report Suspicious Activity to BSA Officer
CTR Form Filing for Two Transactions
CTR on Non-Resident Alien – TIN Required?
CTR Completion - Dollar Amount Used
CTR Exemption - Must Customer Request Exemption?
CTR Exemption Review Form
SAR Filing with FBI or Secret Service
CTR – List Each Conductor?
Wire Transfer - Name on CTR
Biennial Exemption of a Government Agency?
Old Customer, New Signature Card. CIP Required?
Accounting for CTR Exemptions
CTR - Deposit of Check Made to Cash
File a SAR on a Loan Officer?
Please Define Phase I & Phase II Exemptions
Phase 1 Exemptions- Statement of Condition
CTR Filed on Exempt Customer
Monetary Instrument Log Record Retention
BSA Log - Convenience Signer Deposits
Law Enforcement & SAR Disclosures
Proof of BSA/AML and Compliance Training
BSA/AML Violations - Penalties/Prison Terms
Business Purpose Statement Form
Penalties for Not Filing SARs
Tainted Appraisal?
CTR on a Rep Payee Account Q & A - Follow Up
Small Cash Deposits Totaling Over $10,000
File a SAR on Levied/Garnished Customer?
Does Exemption Apply to All Banks Under the BHC?
Unfamiliar Forms
CTR or Bond Redemption - Non-Customer File
File a CTR on Friends/Family or Just Depositor?
Check Kiting Case - SAR Reporting Time Frame
Filing CTRs with DBAs – Most Current Ruling
CTR on Spousal Sole Proprietorship Account
Check Payable to Two Individuals – File a CTR?
The Woman in the Lobby – File a CTR?
SAR Filing – Time Limit
Include the Minor on the CTR?
Best Job Candidate for BSA Officer
Pre-CIP Accounts
Phase II Exemption Debate
SARry Situation – Include Both Accounts?
Include Beneficiary on the CTR?
Can We Combine our BSA, OFAC & CIP Policies?
CTR - Separate Deposits in Same Owner LLCs
Pouch Activities Risk
Customer Address on the CTR
Seasonal Exemption
Customer Identification Programs
CIP Notice Verbiage
ATM Withdrawal Triggers CTR Filing?
OFAC Check on Plan Beneficiaries
Complete a CTR & MIL?
IRS Requesting a Copy of a CTR
BSA Dept Dictating Check Cashing Procedures
SAR Reporting on Forced Balancing
CTR on a Courier Service
Recording Transactions in a Monetary Instrument Log
BSA Training for IT & HR?
University Health Science Center Account
ATM Fraud
Documenting Business Activity without Filing SARs
Are My Transactions "Suspicious Activity"?
CTR on a Non-profit Organization
Need CTR Filing Help
Answering Another Bank's BSA/AML Queries
SAR & CTR Required?
SAR - All the Deposit Details?
Account Closing Form Letter Due to SAR Filing
Is the "Individual" a Consumer or a Business?
Exempt Customer Purchased by Non-exempt Company
USA Patriot Act Signage
Does this Add Up to a CTR?
Insurance Companies and Anti-Money Laundering
Phase I Exemptions Permanently Exempted?
BSA Recordkeeping - Same Day Transactions Only?
Inform Client of CTR Filing?
Purchase of Monetary Instrument Under $3000
Gift Cards - Monetary Instruments?
Unknown Depositor - CTR Filing
Not Renewing Exemption - FinCEN Notification
BSA Retention Policy & Loan Documents
Government Lists for 314a Search Requirements
Avoiding AML and OFAC Risks
CTR Reporting - Never Exempt
SAR Required on One Time Deposit or Withdrawal?
SAR Filing on Suspicious Activity Under $5000
Exempting Once & Future Transactions
Is Private Banking Risky?
Effective Date of CIP Physical Address Rule
SAR'd Customer Eligible for a Phase II Exemption?
POA CIP Requirements
When must a Casino file a Currency Transaction Report (CTRC)?
CTR on Deposits into Personal & Business Accounts
Close the Accounts to Be on the Safe Side?
Commercial Loan Record Retention
New SAR Form Still on Hold?
CTR Completed in the Name Of?
Casinos Compliance with BSA/AML legislation and the MLSA
When should the Bank file a Currency Transaction Report (CTR)?
CTR Reporting on Owners of Tax Exempt Organization
When should the Bank file a Suspicious Activity Report (SAR)?
CTR - 2 $9000 Checks Cashed at Different Branches
CTR on Incoming Wires
Aggregate the Transactions & File a CTR?
BSA Board Training
CTR on a Representative Payee Account
A Business Cashing Customer's Checks
OFAC - Credit Limit Increase
LLC Account Opening
BSA Exemption - Cash for Vault Replenishment
BSA Violations - Civil Money Penalties
Is Our BSA/AML Risk Assessment Adequate?
CTR Filing on a Two Owner Business
Safe Deposit Box & BSA Reporting
Opening New Accounts Via Mail
Wire Transfer - CTR Required?
Filing a SAR on a One Owner Business
PEP List Scanning For Your Customers
Designating a Security Officer
Interagency BSA (Bank Secrecy Act) Guidance
BSA in Job Descriptions and Evaluations
Verbal Request from the FBI
CIP Info When Adding Account Owner
Interagency BSA (Bank Secrecy Act) Guidance
Reporting SARs to the Board of Directors
MSB - Out of Country Wire Transfers
CTR on a Family Trust
CIP on Shared Loan
CIP - Public or Government Account Signers
CTR - Employees Cashing Payroll Checks
CIP on Denied or Withdrawn Loan?
Structuring - SAR Filing & Board Notification
About the Bank Secrecy Act Enforcement Policy
CTR Exemption List - Informing Customers
Lost CTR
To File or Not to File?
PEPs and Potential Risk
Amending an Exemption
IRS Agent Blabs SAR Filing to Customer
Non-Bank Financial Institution (NBFI) clients
Phase II Exemption - Same Owners, Different TIN
Furniture Store Acting as a MSB
Proof of BSA/AML and Compliance Training
Filing a SAR on Customer with a Fake SSN
CTR Filing on Separate Deposits
Setting Scoring Thresholds Based on Risk for Automated Customer Identification Program (CIP) Screening Software Tools
USA PATRIOT Act Confusion
CTR - Original Transaction or Combined Transaction
CIP on Municipal Account Authorized Signers
CIP Requirements- 4 Basic Criteria on all Signers?
CTR on Night Deposits & In-person Deposits
What Does MLRS Stand For?
CIP - Church Youth Group Account
Correcting an Unnecessarily Filed CTR
How to Prepare for the New SAR
CIP Proof in the File
SAR Form Deadline
Exempting Seasonal Businesses
To File or Not to File, That is the Question
Wire Transfers - OFAC Bank Name Check
Treat Them as an MSB?
Branch Isn't Following OFAC Procedures
Close the Account or Continue Filing SARs?
OFAC on Payees that Bank is Paying
Pyramid Investment Scheme - File a SAR?
Would Customer’s Regularity Warrant a SAR?
CTR on Euros
CTR - Savings Bond Purchased for Spouse
Filing a CTR on a Cash Advance
Is a Bank an MSB?
Business Customer Exemption
HR 323 & CTR Exemptions of Seasoned Customers
Do We File a CTR When Multiple Checks are Cashed?
Date Used in Second SAR Filing
CTR - Customer Notification
Filing a CTR - Check is Over a Year Old
CIP on Authorized Signer
Title Companies Required to file CTRs & SARs?
CIP on Safe Deposit Box Signer
CU Considered a Bank for Phase I Exemption?
CTR Pamphlet
"Reasonable Effort?"
BSA: Report Change in Procedure to the Board?
SAR = Something Ain't Right
CTR Completion Guidance
Exemptions and a Newly Acquired Bank
Filling Out a CTR - Customer Query
BSA Exemption List Removal
CTR Filing - Deposit Made After Check Cashing
Savings Withdrawal - CTR Required?
OFAC Check on Purchaser & Payee
CTR Exemption Extends to New Business?
CTR Reporting Exemptions for Sole Proprietorships
Different Accounts, Same Owner-CTR?
New SAR Form
CIP Form Record Retention
File a SAR In Lieu of a CTR?
CTR - DBA Account
Monetary Instrument Sales Form and Log
15 Days to File a CTR - Calendar or Business Days?
File a SAR In Lieu of a CTR?
CTR Reporting – Exempt Organizations
CIP - Indian Tribe Account
Occupation "Retired"?
Imaged Copies of ID
HMDA, HELOCs and Monitoring Information
CTR - Info From Both Account Holders Required?
New SAR Form Announced
Monitoring & Filing Supplemental SARS
File a SAR After Filing a CTR
Definition of Structuring
Anonymous 'Remitter'?
If Transactions are Over $3,000, Make a Copy?
AML/BSA - Correspondent Bank Certification
CIP on Purchased Loans
CIP Notices on State Chartered CU's Website
Filing CTRs on Joint Accounts
Telling Customers the Bank is Filing a CTR
$5000 counterfeit check - File a SAR?
Statement of Purpose
Copy of Drivers License in the Credit File
OFAC Check on the Remitter
BSA - Running Tickets During Currency Exchange
2 Deposits in 2 Accounts on the Same Day, CTR?
BSA - Copying Driver's License for Each Loan
PODs on the CTR?
The Whats & Hows of MSBs
Real Estate Loan Record Retention
BSA Officer Reporting Directly to BOD
Co-mingled Funds
Shady Auto Loan Customer
False Positives throwing off Compliance List Screening for OFAC
Second ID for Existing Customers
Legalities of Copying a Driver's License
Training Requirements
BSA Training for Board of Directors
SAR Filing on Counterfeit Checks
Safe Deposit Boxes - CTR Required?
Aggregation for BSA Thresholds
The USA PATRIOT Act & the Irate Customer
Required Law Enforcement ID for an MIL
CTR Information on Absent Account Owner
Getting Around ID & SSN Requirments
Deposit into Business & Personal Account, CTR Required?
A Customer Wants a Copy of a CTR
Customer Frequently Changes His Address
Filing SARs & CTRs Online
CTR on a Night Deposit
OFAC on Beneficiaries of an Employee Benefit Plan
Do We File a CTR on Another Bank?
CIP & Loan Participations
SAR - Our Bank Name Printed on Counterfeit Checks
BSA Compliance on a Check Cashing Business
Is There a Good Checklist of the Requirements for BSA Training?
BSA Exemption: One ID Number for Multiple DBAs
CIP & Brokered Deposits
Assigning a High Risk Rating to a Repeat SAR Suspect
SAR Filed on Insider, Who Can Sign It?
Cashier's Check Subject to CTR Reporting?
Scan the Signature Card, Keep the Original?
What Constitutes a Monetary Instrument
Exempt Customers of Acquired Bank
Changing Signatures on Business Accounts
CTR on a Long Time Customer Who Doesn't Have an ID
AML - Non-customer Currency Exchange
Deadline for Customer Due Diligence & Risk Rating
Senior Level BSA Officer
Exemption Revoked?
Loan was Denied. Do We Still File a SAR?
Completing/Maintaining a Monetary Instruments Log
OFAC - Non-customer Check Cashing
Rule/Reg Regarding 90 Day Review on Submitted SARs
Refusing Suspicious Deposits
SARS - When Does 30 Days Begin?
How do we Justify our Perceived Risk Rating?
Deposits into Exempt Account & Non-exempt Account
Keeping Copies of Drivers Licenses with Loan Docs
The Owner, the Employee and the CTR
BSA & OFAC - Loans Purchased From Another FI
CIP - Privately Held Co. Owned by Publicly Held Co
Monetary Instrument Purchased by Employee
Filing Additional SARs
Is Beneficiary’s Street Address Required?
Retention of Cashier's Check Log
IOLTA - Beneficiary for CTR purposes?
Payroll Cards - CIP on Business or Employee?
I'm Cleaning up our CIP Files
Former Customer Opens Account, No CIP?
Keeping Photocopies of Sold Loans
Prudent Banking Policy or Encouraging Structuring
Consequences of AML Non-compliance
CIP Audit Information
Do We File a New Designation of Exemption?
Should Banks Develop an Exempt Persons List?
BHC Merging Banks -Refiling Current Exempt Persons
MSB Risk Assessment on Business Loan Customers?
BSA: Should We Be Doing This?
Record Keeping of OFAC Screen Prints


External Auditors Reviewing SARS Filed in 2005
Is this Structuring?
CIP and IDs(PDF)
Reporting MSB/High Risk Accounts to the Board
CTR on Deposits in Personal & Partnership Accounts
Are Additional Signers Included on the CTR?
CIP on Business Loan
Related Entities and BSA
Licensure Verification for a NBFI/MSB
List of Regs Requiring Training
This SAR Has Been Sanitized.........
Please Define: Domestic Correspondent Account
CIP for 1031 Exchanges
Checking "PUPID" Wires Against the OFAC List
SAR Confidentiality
SAR Filing
Learn How to Write Reasonable Explanations
Under BSA are Savings Bonds a Monetary Instrument?
Bank of New York Pays to Avoid Criminal Charges
Looking for BSA Risk Assessment Procedures
Filling Out A CTR
Safe SARs
Service v. OFAC?
Guru Chatter on BSA (pdf)
CTR - BHC Tracking Deposits Across Bank Lines
314(b) Filer
Downloadable Version of the CTR Exemption Form
CTRs: Collecting Information Without the Customer
BSA Record Keeping Requirements on Loans
Accurately Filing a CTR on Uncooperative Customer
CTRs: Documenting ‘Known’ Customers
Guru Says "Annual Reviews Required", Is this True?
Do We the File CTR on both Minor and Parent?
Exempt Customer Purchases New Business
Does Depositing Third Party Checks Trigger BSA?
Cashing Checks for a Fee, Register as an MSB?
To ID or Not to ID Existing Customers
CTR for a Customer with a Hyphenated Name
Level of Account Monitoring to Comply w/BSA/AM
Record Keeping on Paid Loans
Purpose for Closed-End Home Equity Loan
Reasons for Filing a SAR
Section 326 and Grandfathered Account Owners
Aggregation for Different Businesses, Same Owner
How Does a Bank Determine If It Is In a HIFCA?
Annual Reviews on Phase I Exempt Customer
Does Bank File SAR for Scammed Customer?
Is SAR Required on Crime With No Known Suspect?
Patriot Act - Two Forms of ID to Open Account?
CTR for Cash Back Transaction
Guidelines on Exemption Reviews Sought
Time Frame to File an SAR
Do We File Two Designation of Exemption Forms?
Check OFAC on Payee of Every Monetary Instrument
Requiring IRS Subpoena on Information Not in SAR
Phase 1 Exempt Business Going Thru Reorganization
Automatically Exempting Customers w/ the Same TIN
Guru Chatter on BSA (pdf)
Obligations for Possible MSB
Enhanced Due Diligence on a 34 Act Company MSB?
Just an Ice Cream Parlor or an MSB?
CIP Verification and the Four Big Items
SAR on Customer Trying to "Game" Chexsystems?
Section 326 Revisited
314(a) Record Retention
Writing to Your Unregistered MSBs
Negative Database Defined
Small Banks Have New Wire Transfer Tool
Action Audit
Anti-Money Laundering Has Come A Long Way
FinCEN Taps Bank for Penalty
Documenting ATM Deposits
Who is Listed on the CTR?
Disclosing BSA Limits to Customers
Collecting Data From MSB Accounts
Aggregating Transactions for CTR Filings
Wire to Exempt Government Agency
SAR Investigations on 314(a) Matches
BSA Training for Trust Area
CTRs for Individual Depositing to Exempt Accounts
CIP and Government Request Procedures
Dropping a Customer from Exempt List
Reviewing Phase I Exemptions
Is Visiting a Business a BSA Requirement?
Reporting a Beneficiary on a CTR
Received Advice to Buy Multiple Cashier's Checks
CTRs When Deposit is to Joint Account
BSA Training Is For Everyone!
I Changed My Mind
Definition of "Tamper-Resistant Lock"
Required Privacy Training
Recommended Initial Training
Due Diligence on MSB Customers
$3,000 Log, Include the Fee?
CTR Required for Check Cashing
New Account Information
Is armored transportation an MSB?
Using Certified Mail for Filing CTRs
BSA Exam Procedures for CIP
Can We Disclose We Want To Exempt a BSA
Documenting a BSA Exemption
AML Policies, Procedures for an MSB
Tribes Which Are CTR-Exempt
Aggregating multiple branch cash activity
CTR Instructions for a Minor's Account
Exempting Correspondent Banks
What are the new BSA Examination Procedures for Customer ID Programs?
Possible Employee Structuring, SAR-able
The Best Way to File a SAR or a CTR
Concealing CTR Filing from the Customer
BSA Requirement: Identifying Currency on Deposit Tickets
Tricks to Identify High-Risk AML Accounts
BSA Exemption Biennial Filing Question
Exempt or SAR this Commercial Customer?
Accepting Accounts and Relationships
Filing a SAR for Payroll Fraud
Exempting a Foreign Owned Company
$3,000 Cash Sales Record Requirement Clarified: Cash Deposit / Debit Now Must Be Recorded
If It is a Bad SSN, Do We File a SAR?
BSA Training Requirements
Guru Compilation: CIP (PDF)
Guru Compilation: BSA (PDF)
Guru Compilation: CTRs(PDF)
Designation of Exempt Person
BSA Exemption of Govt Entities
Section 326 Takes Over: "The Devil Is In The Details"
Risk Assessment Challenge: How Much Risk is "Reasonable and Practicable?"
Special Terrorism Reporting Number
Requiring an SSN is a Violation of Law, He Says
Ongoing Reviews and SAR Follow-Up
Check Cashiers CIP Requirements
Cashier's Checks: Collecting Verification Info For Known Customers
Developing A Successful Bank Secrecy Program: To Catch A Crook, Think Like One
Back-filing CTR Instructions
CIP Rules Define 'Customer'
Important Exception to BSA Rule EXPIRES
CTRs on Checks Cashed by Noncustomer Payee
OTB Exemption for CTR Reporting
Exchange and Deposit Totaling Over $10,000
Activity History Needed for CTR Exemptions
Designation of Exempt Person
Public Schools and CTR Exemptions
Completing CTR Correctly on Check Cashing
Completing a CTR for Aggregated Transactions
Understanding Multiple Transactions and CTRs
Multiple Currencies and New CTR Form 104
Dollar Threshold for Check Kiting SAR
Format for CTR Form Submissions
Full Disclosure of SAR Content
Examples of Recognizing Suspicious Activities
CTR for Weekend/Monday Deposits
Deposit to Joint Account Triggering CTR
Posting CIP Notices in Branches
Section 326: Where is the government list?
Aggregating Deposits of Chain Restaurants
Timing Triggers for SARs
CTR When Cashing Checks for Others
BSA Enforcement: Expensive!
Giving a Customer a Copy of a CTR
CTR Required for Cashing Loan Proceeds Check?
Smurfing
Naming BSA Officer in Your Policy
Getting a Copy of a CTR
FinCEN Expands E-Filing System: BSA Reports Can Now Be Filed Over Secure Internet
BSA Enforcement
Retaining Records Regarding Forgeries
314(a) Search Request Questions
Reportability of Cash Deposits into Two Accounts
Important Exception to BSA Rule Extended
BSA Exams: Lessons Learned by Experts
BSA Compliance Matters
Completing a CTR for Joint Account Deposits
Internal Theft & Filing SARs
New SAR Form and Software
Suspicious Activity & Stop Payments
CIP & SAR Filing Requirements
CTR, Exempt Person Form, and Reportable Transactions
Designing the BSA program to respond to risk
Penalties for CIP Violations
Tips for Ensuring an Effective Anti-Money Laundering Program
Using a Facsimile SAR
Are CTR Exemptions Mandatory?
Fines for CIP Noncompliance
Current CTR Form Expires?
CTRs & "Multiple Transactions"
CTR on an Estate Account
Training To File SARs
Filing SARs for Stopped Nigerian Scam
OFAC: The New Compliance Hot Seat
SAR Triggered by Invalid SSN?
CTRs & Split Deposits
Attorney-client Privilege & Filing a CTR
Filing CTRs for Armored Car Currency Deliveries
BSA Enforcement: Expensive!
BSA Compliance Matters
BSA Exemption Analysis
Annual BSA Program Approval?
E-filing your BSA reports (PACS)
BSA, Exempted Business Accounts, and Change of Address
BSA TIN Requirement & Religious Beliefs
Required BSA Records
What's the difference between KYC & CIP?
BSA & Customs Form 4790
Non-Resident Signer With No SSN
BSA & Recording The Amount of Currency
Updated BSA Audit Procedures
Updating BSA Policies To Accommodate Section 326 Rule
Amending BSA Policy to Include Section 314(a) Requests
Interstate Banking and CRA Notices
CTR Exempt List: How should you handle an exempt customer that no longer makes frequent cash deposits?
If payroll checks cashed for a business exceeds $10,000 in one day, does this need to be reported on a CTR?
BSA/OFAC Lessons from Enforcement Actions
TIN Requirements For Nonprofit Organizations
Consequences of wrongfully granted BSA exemption
BSA: Wire Transfer Area Software
Is a loan application always required?
CTR Reporting: Aggregating Deposits & Withdrawals
Should we invest in a name matching software system?
BSA: Should we file a late CTR if we discover an error on an old transaction?
Cash Purchases, BSA, and Filing Requirements
Under BSA, what is a sub-account holder?
Account transactions, BSA, and Documentation
Policies That Satisfy USA PATRIOT Act and BSA
USA PATRIOT Act Identification Requirements
Legal Documents In The BSA Exempt File
BSA Brochures For Consumers
BSA/ OFAC Lessons from Enforcement Actions
Anti-Money Laundering Program
The 120 Hour Rule
Lending Disclosures at a Glance
BSA/ OFAC Lessons from Enforcement Actions
What a BSA Officer Should Be Doing Now
ID Requirements For BSA Compliance
Information Sharing: Should You Certify?
AML Policy Requirement
PATRIOT Act AML Rules
Board Approval for BSA Policy Changes
BSA Audit Requirements
No Shortcuts for Updating BSA Policy
Ineligible Businesses and BSA Exemptions
Qualifications for a BSA Officer
BSA Reporting Software
BSA Brochure For Consumers
Exemption Lists For Correspondent Banks
Exemptions & CTR Filing Requirements
FinCEN Advisories
BSA and The Beatles -- A Training Exercise
BSA - Practice Makes Perfect
The ABCs of BSA
BSA and The Beatles -- A Training Exercise
BSA - Practice Makes Perfect
We have to search for suspicious activity. Who says?
Exempt Persons: Manually Monitoring Transactions
Knowing What's Up with Know Your Customer
FinCEN Issues more BSA Q&As
Question & Answer
New SAR
COMPLIANCE NOTES - Keep Sight of the Goal
KYC: Gone But Not Forgotten
Question & Answer
COMPLIANCE NOTES - Where's That CTR Warehouse?
Question & Answer
COMPLIANCE NOTES - Don't Overlook Private Banking
Question & Answer
What's Ahead In Compliance BSA, KYC: Staying Power
Common Violations OCC Warnings On BSA Compliance
EDITORIAL - The Unknown About Know Your Customer
Question & Answer
Question & Answer
Question & Answer
COMPLIANCE NOTES - Zap In That CTR
Question & Answer
COMPLIANCE NOTES - Leading Reasons for SARs
Final Tier II Exemption Rules Released
EDITORIAL - CTRs: Unnecessary Regulatory Burden?
FinCEN's Acting Director
CTRs What Will Phase II Exemptions Really Save?
Question & Answer
Question & Answer
Don't Let SAR Reporting Backfire
COMPLIANCE NOTES - No Exemptions for SARs
Filing SARs How Safe Is The Harbor?
More On the New Compliance World
Question & Answer
Question & Answer
Question & Answer
Question & Answer
Question & Answer
Question & Answer
Question & Answer
Question & Answer
New Itinerary Proposed Changes to the Travel Rule
COMPLIANCE NOTES - $0 CTRs: Status Update
COMPLIANCE NOTES - SARs: Common Violations
KYC
COMPLIANCE NOTES - Annual Cash Aggregation?!
FinCEN Proposes New Exemption Rules
Question & Answer
Know Your Customer Soon - Somehow
COMPLIANCE NOTES - Customer Service v. Suspicious Activity
EDITORIAL - BSA: How Hard Is A Commentary Anyway?
BSA Interested In Helping On The BSA Commentary?
FinCEN Extends Exemption Comment Period
COMPLIANCE NOTES - FRB's BSA Exam Manual Ready!
COMPLIANCE NOTES - What's Going On With BSA At The FRB?
Question & Answer
Question & Answer
Know Your Customer
EDITORIAL - How Safe Are Safe Harbors?
"Drug Czar", General Barry R. McCaffrey
FinCEN, KYC
EDITORIAL - Congratulations To You!
FinCEN Issues Final Rule On Exemptions
Question & Answer
Question & Answer
Question & Answer
Question & Answer
SPECIAL REPORT: The Life and Times of a Currency Transaction Report (CTR)
The Civil Safe Harbor
Suspicious Activity Rules Are Out!
Suspicious Activities: Some Advice on that Safe Harbor Provision
Exemptions: Real Developments At Last
Bank Secrecy Update
New Areas For BSA Attention: "Payable Through Accounts" and "Private Banking"
Question & Answer
Question & Answer
Question & Answer
Get Going on Interim Exemptions
Question & Answer
Question & Answer
Question & Answer
Just Who Is this Customer?
EDITORIAL - Four Minutes Of Your Time…
FinCEN'S CTR First Exemption Rule Final
IN THE NEWS - "First Wave" Exemptions-Timing Clarified
Quesiton & Answer
Question & Answer
Question & Answer
Question & Answer
FinCEN Issues Another New Rule
IN THE NEWS - Bank Secrecy Act Compliance
Question & Answer
Question & Answer
Question & Answer
Question & Answer
Question & Answer
Question & Answer
Treasury's "Glitch"
A New Form - Coming Soon To An Agency Near You - ISCARF
Bank Secrecy Act Update
BSA's Surprising Weak Spot
CTR Update
EDITORIAL - "You have the right to remain silent…"
EDITORIAL - THANK YOU!
Final (!?) CTR Update
Help For Your BSA Exam
New CTR A Reality
CTR and CRF Announced
Question & Answer
Question & Answer
Question & Answer
Question & Answer
Treasury Announces Changes In CTR Exemptions & Wire Transfer Regulations
A New Angle On "Know Your Customer"
FinCEN and OFE Now Partners
Five Necessary Elements For Compliance
New CTR… Finally!
Question & Answer
Question & Answer
Question & Answer
BSA…Still A Hot Issue
EXEMPTION LISTS: First…Consider The Risk
More Bank Secrecy Regulations-Must Identify "Non-Bank" Accounts
Question & Answer
Question & Answer
Question & Answer
Question & Answer
Question & Answer
"Am I In Trouble?"
$950,000 BSA Violation Fine
ABA Horror Story
Don't Go Looking For Trouble!
EDITORIAL - Enough Is Enough!
Even Leona Has To Pay Taxes
Just Doing Their Job
Losers
More On Suspicious Transactions-May…May Not…Must
Question & Answer
Question & Answer
Question & Answer
Still Want Exemptions?
The Ain't Misbehavin' Referral Form?
The Bank $ecrecy Act & Money Laundering
The Figures Are In
They Get It All
WHAT DO OTHER BANKERS DO? - A Nice Arrangement
C A M E L
Checks Become Cash-For Businesses Only
Get Rid Of Your Exempt Lists!
My Customer Is Laundering Money…Should We Close The Account?
FINAL RULE…FINALLY ADOPTED!
How To Launder Money…
Late Breaking News On Bank Secrecy…
More Changes To The BANK SECRECY ACT!
New Bank Secrecy Legislation Passed!
Ring Up That Sale!
Suspicious Transaction: To file, or not to file…
The $3000 Rule-It's Just Around The Corner
Update...Bank Security Act..."Death Penalty Law"
Criminal Referral Forms & FDIC
Your Customers Need Your Help!

See also Money Laundering


Bank Services
Deposit Pick Up
Selling Merchandise in Bank's Branches
Creditor of the Year
And Now A Word From Our Sponsor
"Free" Checking Account
Rules For Free Checking?
Automated Bill Payments
Cheap Checks: Not A Bargain!
Emergency Money Which Method Is Best?
FAX Becomes Money Maker…
Full Service Banking On Sunday?
Rent-A-Room…


Basel Capital Accord
Preparing Now for the New Basel Capital Accord

Beneficiary
CIP for Irrevocable Trust
CTR - Attorney State Bar Client Trust Account
Outgoing Wire Transfer - Physical Address Required
Deposit Insurance -Joint Account Two Beneficiaries
CTR on a Rep Payee Account Q & A - Follow Up
What if POD Precedes Owner in Death?
Check Payable to Two Individuals – File a CTR?
Include Beneficiary on the CTR?
Both IRA Owner & Beneficiary are Deceased
OFAC Check on Plan Beneficiaries
Deposit Accounts - Adding Contingent Beneficiaries
Naming Beneficiary as Attorney-in-Fact
Beneficiary on a Demand Deposit Account
IRA - Husband and Child Beneficiaries
Beneficiaries Disclaiming Account Ownership
IRA Payout to Contingent Beneficiary
POD Designation & Probate
OFAC on Account Beneficiary
Living Trust - CIP the Beneficiaries?
LLC with a POD?
POD's Whereabouts Unknown
What does TOD Mean?
Beneficiary Access to UTMA Funds
Required Beneficiary Info for CIP & KYC
Deposit Check Payable to Trust in Personal Account
ITF & POD Beneficiary Designation
Customer Re-sign the Card if Beneficiary is Added?
OFAC on Beneficiaries of an Employee Benefit Plan
ID Procedures for CD Beneficiaries
Beneficiary Information for POD or ITF Accounts
What's the Difference Between a Totten Trust & POD
Offset of Account with a POD Beneficiary
POD Beneficiary Signing Security Agreement
Is Beneficiary’s Street Address Required?
Step Children as Qualifying Beneficiaries
Authorized Signer Designated as a POD Beneficiary
IRAs (PDF)
Death of a Sole Proprietor
Handling POD CDs when owner dies
OFAC, IOLTAs & Non-Customer Beneficiary Tax ID#
Beneficiary Paying Early Withdrawal Penalty on CD
Beneficiary Withdrawals & Representative Payee Accounts
Is the Beneficiary of an IRA Taxed on Distribution
Beneficiary Rules on Proprietorship Accounts
Annual IRA Beneficiary Review
Family Trust as Beneficiary?
Reporting a Beneficiary on a CTR
POD CDs: Handling Interest after the Customer has Died
Change of beneficiary on ITF account



Bill Pay
MMDA - Electronic Conversions & Bill Payments
Reg E Guidelines & Online Bill Pay
Bill Pay Automation: New Automated Solutions have Banks Learning from Retailers
Medical Billing Service Account
Regs & Disclosures for Internet Banking Bill Pay
Sign Up for Free Bill Pay/Get Entered in a Drawing
Should you automate your bill-pay traffic?
How Do I Handle Bill-Pay Traffic?
Bill pay stop order
Ad for Mortgage with Discount for Autopay
Disclosing ODP Via E- Bill Pay & POS Transactions
Record Retention for Internet Banking & Bill Payment
Online Bill Paying Rises - Good for the Environment
Bill Payment Fee Disclosure
IS eBill Payment by Check Covered by Reg. E?
Online Bill Payment At All-Time High
Differences Between Bill Pay and Online Checks
A Less Painful Collection Method
Written Notice for Changing Equity Line Terms
Online Bill Payment & Outstanding Checks
Automated Bill Payments


Biometrics
Findings of the International Study on Identity Fraud
"New" Keyless, Biometric Safe Deposit Access System
My Customer's Identity has been Stolen! How Can I Detect if Subsequent Activity is Real?
Isn't "Information Security" Just Good Old Fashioned Common Sense?
Filing By Touch
Second Layer of Password Protection
A New Use for Biometrics
Spending on Biometrics Climbing Rapidly
Biometrics as Passwords
Getting Under the Skin
Biometric Payments Tested in Multiple Locations
Three Identity Protection Ideas
Biometrics Hot New Government ID
Budget? What Budget?
Double Edged Protection
Identification & Access: Security Still of Primary Concern
New Standard for Biometric Information Issued


Board of Directors
Loan to Entity - Demand Clause Required
Reporting HMDA Data to the Board
Bank Protection Act - File Annual Report to FDIC?
Advisory Director Liability
BOD's Loan Modification
Reporting SARs to the Board of Directors
Reg O - Bancshares as Collateral
Executive Officer/Director Overdraft Limits
BSA: Report Change in Procedure to the Board?
Signer Adding Signer?
Bank Policies Approved by the Board
BSA Officer Reporting Directly to BOD
BSA Training for Board of Directors
Recruiting a New Board Member? Here’s a Checklist for Success.
Discussing Loans with Father of Debtor, Privacy Violation?
Board Training Program
Maximum Number of Board Members
Lending Reports to the Board of Directors
Board Information, Security Issues
Reg O and Overdraft Fees (Not) Charged
Board of Directors Liability
Origin of Requirement for SAR Reports to Board
Guidance For The Annual Security Report To Board
What designated officers are required?
Non-Board Members At A Board Meeting: Any special resolution required?
Bank Policies Requiring Board Approval
EDITORIAL - Would You Like To Serve On Our Board?


Bomb Threats
Required Annual Employee Security Training
Not A Live Wire
Kidnapping, Extortion and Bomb Threat Policies
Being Ready for Bomb Threats
In The News… - Don't Touch It And Don't Move It !
In Case Of A Bomb…


Bonuses
Bonus to Open for Existing Customers
Is a Gift a Bonus?
Recovering a Bonus for Early Closure
TISA Disclosures
Regulation Q - Advertising
Bonus or Not?
Advertising a CD Special
New Account Cash Bonus & the Toaster Rule
CountryFest Tickets
Sweepstakes - Bonus?
Charitable Contributions
Charitable Contributions Considered a Bonus?
Bonus on Account - Disclosure for 1099?
Bonus vs Interest
Additional Terms Triggered by the Word Bonus?
Bonuses received for "Free"
Reg Q - Cash Bonuses for Opening Accounts
$100 for Opening an Account with Direct Deposit
Reg DD & Advertising
Wording on Billboard Advertising
Reg DD & Advertising
New Account Promo - $25 Gift Card Bonus
CD and Gift
IRS Reporting - Customer Referral Cash Bonuses
Bonuses on an Account
1099 Form - Maximum Dollar Giveaway?
Reg DD - Bonus Offered on a Non-Interest Account
Bonuses On an Account
Reg DD Bonuses
Bonuses on an account
Reg Q Bonuses/Premiums & Bank Merger
Gift Card Bonus to Loan Customers
APY Disclosure of Promo Bonus
Maximum Non-Taxable Amount for New Mortgage Bonus
Compliance Tips for Advertising and Marketing Deposit Products
Bonus Gift Cards
New Account Opening: Is a check buy-back considered a "bonus"?
Exercise Caution in Disclosing "Bonus Rates"
Toasters, Teddy Bears and Other Freebies


Branches
Branch Advertising
Mobile Branch Account Transfers
CRA Public File - List for Branches
CRA Branch Lobby Notice
New Branch Grand Opening
In Branch Advertising
Lending Office Issuing Cashier's Checks
Source to Generate New Banking Business
Financial Institution Regulation Defined
Employee Branch Opening and Closing
Bank Owned Property
One Person at the Branch
Phone Center Robbery Procedures
Foreign Bank with US Branches
CRA Branch Notice Requirements
CRA - Complaint & Response In Branch Files
Deposit Pick Up
Small Banks, Big Business: Cash Management or Currency Management?
New Branch Opening - New Car Giveaway
Branch Closing - Safe Deposit Box Procedures
How can branch layout standardization promote operating efficiencies?
All Alone Am I -- At My Branch
Self-Service Technology: Credit Unions and Banks Focus on Different Self-Service Needs
Marketing In The Aisles: In-Store Branch Compliance
The New Face of Banking: The Well-Trained Teller
Closing a Branch Early, Notice Requirements
Reg O Applying to Foreign Bank Branch in the U.S.
"We've Stepped Out -- Back in an Hour"
Credit Unions Network to Provide Branching
All Alone Am I -- At My Branch
You say you want a revolution? Bank Tellers are on the Front Lines of Branch Renewal
Community Banks Define Success Through Design
Lobby Posters in an LPO of a National Bank
Closing Branch to Repave Parking Lot
The Traveling New Accounts Representative
Guidance on Branch Operations Hours Requested
Aggregating multiple branch cash activity
The Impact of Branch Capture
Facility Requirements -- Bank Protection Act
Free Non-Cash Courier for Customers
Security Tips for Supermarket Branches
Ratio of Security Officers to Branches
Posting CIP Notices in Branches
Loan disclosures & state law
Staying Open in the Event of a Power Outage
New Branches & CRA/HMDA Reporting
Convenience To The Max
Security Issue - Branch With Only 2 Employees
Boeing CU Opens "Tellerless" Centers


Budget
Bank Marketing Expenses
Marketing Budget Benchmark
How can you control ongoing capital spending against your planned budget?
When is it time to implement a capital spend management system?
Gaining power through your budget
Budget? What Budget?
The Ostrich Syndrome


Business Accounts/Checks
FI Dictating Business Signer Changes?
Account Closing – Pay Check to Signer or Business?
TISA - Business Accounts
Reg CC Holds – Personal Vs Business Accounts
DBA Account - Authorized Signer Removal
POD’s on S Corporations
Business Account Designating a Beneficiary
Corporate Business Account - FDIC Insured?
Opening Business Accounts
Reg CC - New Account
Business Transactions Via Personal Accounts
BSA Log - Convenience Signer Deposits
Now Account for Non-Incorporated Business
Accepting Check Endorsed "Paid to the Order of…"
Business Accounts - Charging Daily Interest
Check Paid to 2 Businesses Endorsed by 1 Business
Temporarily Restricting Signer's Withdrawal Access
Totally Free Business Checking
BSA Dept Dictating Check Cashing Procedures
Authorized Signer Questions
Same Check - Two Different Amounts
Signer Depositing Checks into Business Account
Deposit of Personal Check into Business Account
Business Identity Theft
Business Debit Cards Linked to Personal Accounts
Business Signing Check Over to an Individual
CTR on Deposits into Personal & Business Accounts
Commercial Account unauthorized transactions
Cashing a Check Made Payable to a Partnership
s Messy Divorces & Business Accounts
A Business Cashing Customer's Checks
SSN for a Single Member LLC?
Paying Interest on Business Account
Checking Accounts - Businesses as Signers
Handling Business Checks
Personal Account to Business Account Auto OD
Filing a SAR on a One Owner Business
Check Cashing by Business Account Signer
Reg E Protection for Business Accounts?
Is There a Regulation Prohibiting...?
Small Business Accounts - ATM &Check Cards
Commercial Customers - Interest Bearing Accounts
Reg D - Business MMDA Checks Made Out to Signers
Corporate Customer/Timeline to Dispute Unauthorized ACH
Deposit & Debit Charges on Free Checking?
Rules for Business ATM Cards
Business Customer & Internet Banking
Corporate Business Interest Checking
Business LLC & DBA - Two Separate Entities?
Cash Back on Business Account Deposits
Different Accounts, Same Owner-CTR?
Joint Business Account of Two Corporations
Covering Personal Overdrafts from Business Account
Signer Adding Signer?
Spousal Business NOW Accounts
Totally Free Business Checking Account?
Reg E - Business Account Internet Transactions
ITF Beneficiary on a Business Account?
Is Reg P Applicable to DBA Accounts?
Business Account CIP Files
Depositing Personal Checks into Business Account
Co-mingled Funds
Commercial Account Overdraft Fees
Reg E & Business Debit Card Protection
E-checks Requiring Two Signatures
Medical Billing Service Account
Changing Signatures on Business Accounts
Business Account Debit Card Legal Issues
CIP - Privately Held Co. Owned by Publicly Held Co
Deposit Sole Proprietor Checks in Personal Account
Business Accounts and ODP
Member of Publicly Traded Company Exempt from CIP?
Reg E & Business Check Cards
Deposit personal check to business account?
Issuing Debit Cards to Business Accounts
This Check Is To The Business, Deposit It Please
Which Rules Govern Returned e-Checks?
Restrictions on "Free" Business Checking Accounts
Change in Terms Notice for Business Accounts
Safe Deposit and Corporate Documentation
Regulations Applicable to Business Saving Accounts
Aggregation for Different Businesses, Same Owner
SSN Requirements for Signers
Checks Payable to Me AND You, Me OR You
Charging an Additional Fee for Difficult Deposits
Styling Business Account Owned by Trust
Required Use of Positive Pay
Is Visiting a Business a BSA Requirement?
Removal of an Authorized Signer
Using Check 21 to Capture Commercial Business
OK for MSBs to cash checks to businesses?
Transfer of Business Funds to Personal Account
Proper Use of "The" in The Name
A Lottery or Not?
Depositing Business Checks in a Personal Account
Business Checking Interest
Designation of Exempt Person
Does the Error Resolution Notice Change the Terms?
Depositing a business check into an IOLTA account.
Free Non-Cash Courier for Customers
Sending Business Check Cards
Payees Making Payors Initial Back of Check
NACHA & Business Accounts
Provisional Credit on Business Debit Card
Disputed Access to Business Account
Credit Reports and Business Accounts
Written Policy: Using Rubber Stamps For Signing Business Checks
Keeping Customers After a Merger
Owner Cashing Check Payable to Business
Business Accounts: Is a resolution required for account signers?
Business DDA Accounts, Automated Transfers, and Overdraft Protection
Business Account Authorized Signers Cashing Checks
Check Cashing Business Depositing Checks Payable To Cash
Is there a regulation that addresses depositing a business check into a personal account?
Handling The Suspected Deposit Of Business Checks Into Personal Accounts
Business Accounts: Authorized Signer Information
Negotiating Checks Payable to Businesses
Requirements For Documenting Business Accounts
Pitfalls When Exchanging Corporate Checks For Cashier's Checks
Liability For Stolen Business Checks
Should we allow customers to deposit checks payable to businesses?



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