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denotes Guru Question & Answer.
DBA
NOW Acct for Sole Proprietorship DBA a Corporation
DBA Set Up as a Trust Account
File an Amended Designation of Exemption?
Are Sole Proprietorships & DBAs the Same?
Business LLC & DBA - Two Separate Entities?
CTR - DBA Account
Sole Proprietor Without DBA in the Title
Corporation Wants Four DBAs Under One Account
Same TAX ID Number - 2 Different DBAs
Beneficiary on Sole Proprietorship Accounts

Can a sole proprietorship be owned by a trust?
Living Trusts & Sole Proprietorships

Proper Endorsement for Checks to DBA
New Accounts: Do you need an affidavit of sole proprietorship?
DBA Account Ownership 
LLC Using a Social Security Number
Account Styling SSN vs EIN
Completing CTR for Sole Prop Deposits
Showing a Bank as a DBA 
Using a DBA
Two DBA Accounts with the Same Name
Right of Offset

Do's and Don't's for DBAs
Sample Affidavit of Sole Proprietorship
Business Depositors: Understanding the Differences

Can an authorized signer endorse and cash checks payable to a DBA?
Using DBA On Sole Proprietorship Loans
Structuring A Sole Proprietorship Account


Debit Cards
A Decrease in Check Fraud?
Individual HSA Account - Spousal Debit Card
Protecting Bank from Possible Minor Mischief
Angry & Confused Over Reg E
Fraudulent Purchase - Require a Police Report?
Debit Card for Sole Proprietor
Multiple Cards, One PIN?
Business Debit Cards Linked to Personal Accounts
Rule Restricting Debit Card Gambling Transactions
NSF Return Check Due to Debit Card Hold
Debit Cards, Fraud & Reg E
Consumer Liability Determined by Reg E or Visa?
Debit Card Fraud - Provisional Credit Time Frame
Unauthorized POS Debit
Expired Debit Card - Stolen & Used
Reg E Applicable to HSA Debit Cards?
Customer's Recourse with Merchant 
Parent's Debit Cards, Minors & Internet Purchases
Stolen Debit Card - Refunding Foreign ATM Fees
Reg E & HSAs
Provisional Credit Predicament
Debit Card Reported Stolen - FI's Responsibility
Relative Given Debit Card by Customer
Debit Card on Representative Payee Account
Do We Follow Visa Rules or Reg E? 
Ordering Debit Cards - Signature Required?
Internet Banking Disclosures
Debit Card Fraud - Commercial Customer Recourse
ACH Debit Card Compliance
Representative Payee Debit Card 
Reg D - Monthly PayPal Debit Transactions
Stolen Debit Card - PIN Written on Checkbook
Reg E & Non-resident Aliens
Disclosing Same Day Availability
Asserting a Claim - Signed Notification Required? 
Debit Card Disputes - Require Written Notice? 
ATM/Debit Card Suspension - Customer Notice
Deceased Customer -Stolen Debit Card Transactions
Furnishing Security Info Upon Debit Card Issuance
Debit Card Dispute Transaction Timeframe
Stolen Debit Card - Dispute Denied
Issuing Debit Cards to Commercial Customers
Deny Provisional Credit?
Reg E - Customer Liability for the $50.00 
ATM/Debit Card Agreement
Debit Card Cancellation - Notification Required?
Deny the Claim of an Uncooperative Cardhholder?
Recurring Preauthorized Debit Card Transactions
Jail Bird's Hubby Used Her Debit Card
Disputing Unauthorized Transactions at the Pump
EFT Claim - How Could this be Valid?
Debit/ATM card for a Minor
Exclusions from FFIEC Guidance
Recourse for Unauthorized ATM Withdrawals
Captured Debit Card
Business Debit Card Liability
Free Checking? 
Developing a Debit Card Strategy
Debit Cards and Multi-Factor Authentication 
Debit /ATM Cards for Corporate Account Signers
Debit Card Disclosures 
Reg E and the Intoxicated Customer 
Debit Card or Online Bill Pay & the Bonus Rule
Unauthorized or Revoked ACH Debits
How to Improve Your Bank's Non-Interest Income
Debit/Credit Card - Higher Limit Liabilty
Can we Issue Debit Cards on Savings? 
Gas Pump Debit Card Charge Dilemma
Customer Gave PIN Number to Family Member 
Reg E & Business Debit Card Protection
Time Limit for Debit Card to Clear Account
Customer Hasn't Checked Statement Since Nov 2005
Helping Customer Resolve Stolen ATM Card Issue
Business Account Debit Card Legal Issues
Overdraft Payment Programs and Reg DD
Debit Card Fraud - Refunding Customer's Money
Sample Hold Harmless Agreement
Phishing by Debit Card
When "Unauthorized" are Authorized -- What Then? 
Visa Debit Card ATM Fraud - Reg E or Visa Rules? 
Debit Cards & Commercial Accounts 
Prior Notice on Blocking Access to Debit/ATM Card 
Disputing Customer's Authorized "Temporary" Charge
Disputed Visa Debit Card Transaction Fee
Is Customer Responsible if PIN is on the Card?
Chinese Credit Card
Debit Card Denial 
Debit Card Change In Terms-Before Product Launch
FEMA Debit Card Fact Sheet (PDF)
Customer Liability, Fraudulent Card & Card Number
Customer Negligence and Reg E 
Issuing Debit Cards to Business Accounts
Issuing a Debit Card to POA on an Account
Count Toward the Transaction limit on MMDAs? 
Difference Between POS and Debit Card Transaction 
'Skimming' Too Easy with New Technologies
Outsource Debit Cards/ Required to Comply W/FACTA?
Issuing a Debit Card to POA on an Account
Pros and Cons of HELOC Debit Card Access 
Debit Card Transaction Never Completed
Payment by Key Fob
Retention of Declined Debit Card Applications
Debit Card- Returning Item from Overdraft
Reg E - Debit Card for Trustees of Living Trust
Debit Card Denial Disclosure 
Reg E -Require a Filed Police Report from Customer 
Why not overdraft privilege? 
Issuing Debit Cards to Non-Signers
Customer Gives Up Card Data in Scam 
Stopping debit transactions on closed accounts
Major Payroll Company Offering Cards
Payment at the Table
Debit Card Program for Businesses 
Is MasterCard SecureCode Subject to Reg. E 
"See ID" Instead of Signing the Debit Card 
Reclassifying Savings with EFT Access 
Out With the ATM Card, In With the Debit Card 
Encouraging Debit Card Use in Pakistan 
Debit Card "Notice of Action Taken" 
Freezing a Levied Account from Debits 
Regs Addressing Business Debit Cards 
Sweepstakes 
Gasoline Rebate On Bank Card
Denied Debit Card Rules 
Debit Card in Possession, is it a Valid Claim 
Debit Card Liability
New Debit Card, New Disclosure
Sending Unsolicited Debit Cards
Provisional Credit Days Under VISA 
Debit Card Terms for Safety
Adverse Action on Debit Card Turndowns
Sending Business Check Cards
Minor with a Debit Card
Expiration Date on ATM Card 
Bank Liability When Customer Writes PIN on Card 
Gross Negligence and ATM Disputes 
Provisional Credit on Business Debit Card 
MasterCard To Test 'Contactless' Cards
What Falls Under the Term "Debit Card" 
Resolving Business Debit Card Dispute 
CIP and ATM/Debit Card Accounts 
Debit Cards Tied to HELOCs 
When Cardholder Fails to Report 
Campaign Account and Debit Card 
Reg E Disclosure Revisited 
Restricting an ATM Card
Putting "See ID" on back of card 
Restriction of Card Use After Fraud 
Reg E Disclosures on Web Page 
Bankruptcy: Can we hot card a debit card? 
Stop Payment On Check Card Transactions? 
Denial Forms For Debit Cards
Pre-paid debit cards --- stored value cards? 
Does Reg E Apply to Business Customers? 
Reg E v. Visa: Who Wins?

Adverse action for denial of ATM or debit cards? 
Disputing Transactions On Check Card 
Reducing Check Card Losses 
Debit Card Disclosures For Commercial Customers
Can we offer debit cards to savings accounts customers? 
Accessing HELOC Accounts: DDA Accounts, Debit v. Credit cards, and Unsolicited Delivery 
The Best in Human Nature Can Bring Out the Worst
If a financial institution issues a debit card to a customer who has an existing atm card, is the debit card considered "unsolicitated"? 
ATM Network Logo Posting Requirements 
eCommerce, Debit Cards, and Dispute Resolution

Business Debit Cards 
Account Closing & Debit Card Transactions 
Lost Debit Card Liability 
Reg E Debit Card Disclosure 
Where do you turn for assistance with debit card fraud? 
Preauthorized Debit Card Transaction Rules 
Preauthorization and Debit Cards 
Should Debit Cards be issued on Commercial Accounts? 
Question & Answer
Will It Replace Cash?

Deceased Customer
Deceased Customers - Backup Withholding 
Deceased Customer -Stolen Debit Card Transactions
POD's Whereabouts Unknown
Handling a Reclamation
POD's SSN Required?
Admin Access to Prior Account Activity
Authorized Signer, Deceased Joint Owner
Offset of Account with a POD Beneficiary 
Check Payable to New Customer & Deceased Mother
Trusts and Checks Payable to Estate of Deceased
Customer Deceased, Can We Deposit to the Account? 
Check Fraud on Deceased Customer's Account
Opening an Account for a Deceased Person 
Paying Checks After Death of Depositor 
POD CDs: Handling Interest after the Customer has Died
ACH debits after notice of death 
Who Trumps, POD or Personal Representative? 
Deceased Payee & Forged Endorsement
Authorized Signer, Deceased Account 
Distributing Decedent's IRA to a Trust 
Reporting Large Balance in Account of Decedent 
Jointly Payable Checks Where One is Deceased
IRA Customer Died Before Taking RMD
DNE Notification on ACH 
Guru Chatter on Interest Reporting
Death of Sole Safe Deposit Renter 
Deposits of Decedent's Checks into Joint Account
Deceased Customer Affidavit 
Death of Sole Owner 
Drilling a Deceased Customer's Box 
How should we handle uncashed CD interest checks for a deceased customer? 

Decedents
Decedent Funds
Paying Expenses from Decedents Account
Death of UTMA Custodian
POD Designation & Probate
Signer Rights After Account Owner's Death
What does TOD Mean?
EIN Required on all Estate Accounts?
Handling a Reclamation
POD's SSN Required?
Admin Access to Prior Account Activity
Decedent’s Right to Financial Privacy?
Training All Staff When Acquiring a New Transaction System

Joint Checking and Estate Settlement Problem
Deceased Customers
Minor's Account - Death of the Custodian
Estate Ownership of a Safe Deposit Box
Handling Interest After Demise of Depositor
IRA Check Payee Has Died -- Now What?
Handling POD CDs when owner dies
Trusts and Checks Payable to Estate of Deceased
Where to Deposit a Check Payable to a Decedent
What's the Priority Claim on an Estate?
Opening an Account for a Deceased Person 
Identifying & Freezing a Decedent's Account 
Process to Close a Decedent's CD Account
Paying Checks After Death of Depositor 
TIN for a Burial Trust Account
Authorized Signer, Deceased Account 
Distributing Decedent's IRA to a Trust 
Reporting Large Balance in Account of Decedent 
Access to Decedent's Safe-Deposit Box
After Safe-Deposit Renter Dies
Safe Deposit: Drilling Safe Deposit Box Of A Deceased Owner 
Joint Accounts: How To Handle The Death Of A Joint Owner 
Handling A Reg E Claim If The Claimant Dies
Administering Accounts For Deceased, Non-Probated Single Owners 
Is it a requirement to update joint accounts when one accountholder dies?
Question & Answer
EDITORIAL - Check The Obituary Column, Please
Question & Answer
Quesiton & Answer
Question & Answer
Question & Answer
Question & Answer
Question & Answer

Delinquent Accounts/loans
Mobile Home Loan Default - Demand Letter
Business Loan Collections
COBB Collection Letter
Credit Reporting on Guaranty
SCRA - Finalized HUD Notice
Statutory Bad Debt
Accounting for Fees in Delinquent Payments
When Does A Loan Get Considered Delinquent?
Paying Past Due Taxes and Accruing Interest
It's a Matter of Choice
Protection Against Identity Theft
Contacting Borrower in "Cure" Period 
Taking Delinquent Loan Payments From A CD
Industry Averages For Credit Card Charge Offs
Using a CD to Offset a Delinquent Note 
Collection: Behavioral Scorecard For Delinquent Accounts 

Deposit Accounts
Adding Daughter to Father & Son Joint Account
Authorized Signer's Funds in Owner's Account
VA Reclamation - Obtaining Funds Paid to Survivor
Consumer Driven Healthcare Plans
Deposit Account Required for Loan Approval?
Signers on Estate Accounts
NSF Check Frustration
Deposit of Personal Check into Business Account
Association Account Headaches
Facsimile Signatures
Reg Q Confusion & Competitor's New Account Promo
A Decrease in Check Fraud?
Individual HSA Account - Spousal Debit Card
Exception Hold on Available Funds?
Johnny Appleseed Jr. Ecology Club Program
Paying Funeral Expenses from Revocable Trust
IRS Tax Levy - Funds Less than Amount Levied
Replacement of Stale Dated Money Order
Requiring e-statements on employee accounts
HOAs & the USA Patriot Act
Defining IRETA
Grandfathered NOW Account
Professional Association Interest Checking Account
Returning a Fraudulent Cashier’s Check
Offsetting Two Separate Accounts
NOW Acct for Sole Proprietorship DBA a Corporation
Deposit of Check Payable to Individual & Estate
Inactive & Dormant Accounts - One in the Same?
EIN & SSN - Same Number? 
Please Define "Per Stirpes"
Compounded CD - APY Disclosure
Reg CC Holds & Fraudulent Accounts
Signer Added for Check Writing Purposes Only
Using CML LOC as Overdraft Protection
POA Check Deposit Procedures
Lending DDA Funds
Reg Q - Paying Interest during the Grace Period
IRA - Husband and Child Beneficiaries
Beneficiaries Disclaiming Account Ownership
Exempting Once & Future Transactions
Foreign Accounts – Interest Reporting
IOLTA - Who Handles the Earned Interest?
Business Endorsement Stamp - Required Verbiage
CTR on Deposits into Personal & Business Accounts
Close the Accounts to Be on the Safe Side?
Levy the CDs?
CD Titled in a Trust - Early Withdrawal Penalty
Non-citizen & Citizen Co-owned Account
New Account Promo - Regulations Triggered?
Reg CC - Consumer and Commercial Accounts?
Paying Preferential Interest Rates
Send Out Revised Hold Notices?
IRS Reporting - Customer Referral Cash Bonuses
Minor Withdrawals
Cashing a Check Made Payable to a Partnership
One Owner Garnished - Garnish Joint Account?
Interest Paid on Insider Deposits
Improper LLC Endorsement?
Member Demanding Original Paper Checks
Decedent Funds
Late Return or Not?
Paying Expenses from Decedents Account
Merchant Capture Device - Reg D Transaction Limits
Required Deposit Statement on the TIL
Messy Divorces & Business Accounts
Subpoena - Joint Account Holder Notification
Foreign Exchange Student Account - Acceptable ID
CD Secured Loan - All Owners Sign the Assignment
Account Ownership Change
IRA Changes
Death of UTMA Custodian
IRA Payout to Contingent Beneficiary
Reuse of Consent
Deposits Under $5000 - Case by Case Holds
Reg CC - Counting the Days.....
Difference Between Authorized & Convenient Signer
Communicating with MMDA Customers
LLC Owned MMDA 
Reg E & HSAs
Paying Interest on Business Account
Checking Accounts - Businesses as Signers
Foreign Account Holder - No TIN
Handling Business Checks
Time Frame for Returning a Stale-dated Check
CD Set Off
Sample Excessive Withdrawal Letters/Notices
Personal Account to Business Account Auto OD
FDIC Insurance on POD Accounts
Filing a SAR on a One Owner Business
Minor on JTWROS Account
Issuing a Custodian a Debit Card
Bonuses on an Account
1099 Form - Maximum Dollar Giveaway?
Reopening a Closed Deposit Account
Hold Not Placed at Time of Deposit
Employee Account Privacy
Indicating Cash on Deposit Slip
FDIC Logo Change?
Early Withdrawal Penalty Required?
POA No Longer Wants the Responsiblity
Authorized Signers & Convenience Signers
Changing CD Terms, etc.
Signer Rights After Account Owner's Death
Funds Unavailable - Returning Check
CIP Requirements & Foreign College Students
Deposited Spouse’s Estate Check into His Account
Signer on Individual Account Only?
Timeframe for a Treasury Check Return
CIP Info When Adding Account Owner
Deceased Customers - Backup Withholding 
No Longer Paying Interest - Disclosure Necessary? 
Dormant Accounts - Privacy Notices Required? 
Is There a Regulation Prohibiting...? 
Adding Signers to Trust Accounts 
Levy on Account Receiving SS Deposits 
Disclosures to Business Customers 
Tenant Deposit Account - NOW Eligibility
Commercial Customers - Interest Bearing Accounts
Reg DD Bonuses 
Small Business Accounts - ATM &Check Cards
Car Dealer Reserve Account

Cashing Deceased Spouse's Checks 
Time Frame for Checking Statements
Due Diligence on a Spouse
Durable POA Removing Joint Owner From Account
Authorized Signer's Rights
Due Diligence on a Spouse
Reg D Withdrawal Limits Violation
Pull a Credit Report for an Account
Sole Proprietorships & FCRA Adverse Action Notices
Sole Proprietor Vs Sole Practitioner
Selling Individual Retirement Accounts (IRAs)
Free Checking Advertising - Inactive Account Fee
Giving a Gift Card as a Deposit Premium
Minor MMA
Using Payroll Accounts to Avoid Summons
Identity Theft Red Flags
Account Opening - Written Consent Required?
Disbursing UTMA Funds Without Custodial Approval
POA Documentation
Original Issue Discounts
LLC with a POD?
Phase II Exemption - Same Owners, Different TIN 
Increasing Savings Account Deposits a Must
Stopping an ACH Insurance Debit
Furniture Store Acting as a MSB
CTR Filing on Separate Deposits 
S Corp Interest Bearing Account 
The Benefits of Health Savings Accounting 
Third Party Privacy Hold
USA PATRIOT Act Confusion 
Rate Sheets - Are They Considered Advertisements? 
CTR - Original Transaction or Combined Transaction 
Can We Close the Account after the CD Matures?
Custodian's Funeral Paid by Minor Account?
CTR on Night Deposits & In-person Deposits
Trust Account - Authorized Signer Documentation
Preauthorized EFTs & "Substantially Regular Intervals"
E-Statements
POA Added on a Minor Account?
File an Amended Designation of Exemption?
Displaying FDIC Signage Before the Compliance Date
More Than One Minor on an UTMA?
What does TOD Mean?
Check Deposited into POAs Account
Two Separate LLCs, Same Owner & Same EIN
UTMA Custodian
Treat Them as an MSB?
Power of Attorney on a Joint Account
Wait Until the CD Matures or Close it Now?
Extenuating Circumstances
Direct Deposit of Her Payroll into His Account
Account Closing - Compliance Issues
Close the Account or Continue Filing SARs? 
More than One Executor for an Estate Account? 
Transferring HELOC Funds into Checking Account
Fiduciary Accounts - Ownership & Disclosures
Commercial Internet Banking
What is a Conduit IRA?
Equal Housing Logo - What is it?
Penalty on Interest Credited to CD?
Levy the IOLTA Too? 
Insurance Coverage of Government Deposit Accounts
Do We File a CTR When Multiple Checks are Cashed?
Account Opening - Requesting Email Addresses
Signer Responsible for Charged Off Account?
Cancelling a Stop Pay
Debit Card Cancellation - Notification Required?
Refusing USP Money Orders for Deposit
UTMA with a Co-custodian
Bank Wants to Increase Fees, Disclosures Required?
Are We Aiding Customer in Avoiding a Levy?
"Reasonable Effort?"
Fiduciary Adding a Signer to an Account
Husband & Wife Joint Sole Proprietorship Account
Are Sole Proprietorships & DBAs the Same?
Understanding Factors that Affect Credit Scores
Transfers Subject to Reg D Transfer Limitation
Is Closing an Account Adverse Action?
Designating the Signer on Sole Proprietor Loan
Paying Interest on a DDA
Returned Statement Record Retention
Trigger Term Lapel Pins?
FACTA - ID Theft Procedures
HSA Obligations
CD Documentation
Charging Back a Returned Item to Another Account
List Spouse as "Survivor" not as POD?
Living Outside of US - Monthly Statements
SSI Check Deposit Account Restrictions
Bank Merger - CD Cashing
MMA with a 3 Year Old Signer?
IRA Account Documentation
Free Checking Account Inactivity Fee
Now Account Owned by LLC - Options & Penalties
Service Charge Change Notice
Signing Over a Government Check
Deposit Pick Up
Family Trust - POA’s Authority
FDIC Signage Change
Notifying Customer of Hold
Power of Attorney Appointment 
Notice of Levy Extends to Loans, Too? 
Direct Deposit/Minimum Balance Required 
LLC Owning an Interest Bearing Checking Account
Free Account - Some Restrictions Apply
Hold on a Split Deposit
POA on a Revocable Trust Account
CD Retitled into Living Trust, Withdrawal Penalty?
Ready Reserve Account - Customer Notice
Required Beneficiary Info for CIP & KYC
Bank's Right to Refuse Deposit of Fraudulent Item
Forgery of an Electronically Converted Check
Penalty for Early Closing of Time Deposit Account
Unauthorized Paper Draft/ When Do We Recredit Acct 
Changes for NOW Account Eligibility?
We Are the Business! Now Deposit Our Check!
Decedent’s Right to Financial Privacy?
What are Sweep Accounts and what do I need to consider?
Deposit Disclosure Booklet Surprise
Employee Statements Sent Via Email
Social Security Check Offset
Signature Stamp Liability
Short History of NOW and MMDA Accounts
Recourse Against Account on Returned Check
Corporate Resolutions
What is the Toaster Rule and Requirements?
Is this Transaction Fee a Finance Charge? 
LLC Ownership of a Money Market Deposit Account
Interest Bearing Accounts for Non U.S. Citizens
Is a transaction considered high-risk when… 
Use of "Instuto Federal Electoral Card" as ID
HSA Compliance Issues
Rule to Combine Business & Personal Accounts? 
What Becomes of Matured CDs?
ITF & POD Beneficiary Designation
Training All Staff When Acquiring a New Transaction System

Joint Checking and Estate Settlement Problem
Deceased Customers
Broad Reach of a Garnishment
ID Verification Via Mail for HSAs
Handling Non-receipt of ACH over the Phone
Is an IOLA Account Covered Under FDIC Insurance?
Withdrawal of CD, Modified Terms
More than One Authorized Signer on an Account
Opening a Donation Account
APY Calculations
Offset Corporate Signer’s Personal Account?
Assessing Fees on "No Fee Checking" Accounts
Interest Rate of Loans Secured by Deposit Accounts
Corporation Wants Four DBAs Under One Account
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