Are savings account transactions considered exempt from CTR reporting for the business customer that is an exempt non-listed business? What about cash payments to a loan account?
From 31 CFR 1020.315: The exemptible accounts of a non-listed business or payroll customer include transaction accounts and money market deposit accounts.
From Federal Reserve Act 19(b)(1)(C): The term "transaction account" means a deposit or account on which the depositor or account holder is permitted to make withdrawals by negotiable or transferable instrument, payment orders of withdrawals, telephone transfers, or other similar items for the purpose of making payments or transfers to third persons or others. Such term includes demand deposits, negotiable order of withdrawal accounts, savings deposits subject to automatic transfers and share draft accounts.
If a business customer has a privately owned ATM in their business, are they considered an MSB?
The bank received a phone call from a non-customer who stated that their business email had been compromised as a staff member of theirs received what appeared to be a wire request from the CEO, however, it was discovered that the CEO did not send the request. The request listed our customer and account number as the beneficiary of the wire. Would this be considered an attempt by an unknown subject or because we did not specifically get the wire or the wire request, just a call from a non-customer and an email forwarded from them, would this not be considered reportable?
A customer presents a cash deposit at the teller counter in the amount of $10,000. The teller counts the deposit and discovers it to be $100 over. The customer is made aware and requests the teller to give back the $100. Does this qualify for a CTR since it was handled by the teller while counting the large cash deposit or is it a simple mistake by the customer? We are also considering a SAR for possible structuring by the customer.
When filing a CTR on a business, and only one account signer made the deposit, is it required to get the information on the other signers that were not present to file the CTR?
314a searches need only encompass current accounts and accounts maintained by a named subject during the preceding twelve (12) months, and transactions not linked to an account conducted by a named subject during the preceding six months. How is the information handled for named accounts older than 12 months and with no other relationship?
Can we remove a joint owner of a DDA account if they did not provide CIP information within a reasonable period of time? We have the primary account holder's information so we don't want to close it. However the joint party never returned with their information, even after notices were sent.
We are looking at revising signature cards for an existing HOA management company and their subsidiaries. We are adding an employee and deleting an employee. If the employee is just an authorized signer and not an owner or person in control, do we need to gather or require the beneficial ownership certification?
This relationship was created before the regulation went into effect. We have nothing on file regarding beneficial ownership and are wondering if this would be a “triggering event”?
We have a DBA car dealership that finances the purchase of it's vehicles. Are they considered a Money Services Business?
What is an LEI? Do we have to use it to establish beneficial ownership certification?