08/23/2010
If a POA makes a reportable withdrawal for the custodian on a PUTMA account, we will put the custodian in Section A of the CTR and the POA in Section B. Do we also need to include the beneficiary of the PUTMA in another Section A? We don't know if the money is going to the beneficiary or not.
08/02/2010
Currently, we have nothing in writing (procedure, signature card, disclosure or system) that designates on a regular deposit account in which the funds are to be divided equally among beneficiaries. For an IRA, the customer can designate beneficiaries, but not for a simple deposit account. Is it correct if the accounts with single beneficiaries become single accounts, that accounts with joint beneficiaries become joint accounts; therefore, the beneficiary who gets to the bank first is an authorized signer and can withdraw all the funds?
09/28/2009
Does the Travel Rule apply to incoming wires?
03/30/2009
Why is it that most banks that originate outgoing wire transfers require a physical address (no PO boxes) for the beneficiary? Is this a compliance requirement and if so, where is it established? I have looked at Reg J, the UCC, the BSA exam manual and the travel rule without much luck. The latter proved more helpful than the others, but still offered little justification for the requiring of the beneficiary's physical address. In this regard, the rule states that the originating bank is only required to retain "beneficiary information provided by the requestor" which may or may not include an address. Any help in determining how and/or why this no "PO box policy" was derived would be greatly appreciated.
12/10/2007
When a loan is secured by a certificate of deposit held by the same organization should all names listed on the certificate sign the assignment if the C or D states "or" instead of "and"?
11/19/2007
Will an account with a POD designation avoid probate for the beneficiary?
09/24/2007
The "Wire Transfers and Reg D" question and response regarding whether or not outgoing wire transfers count in the Reg D limits was first published on 12/1/03. In that response, it was noted "if the request is presented at the bank in person or by customer-hired messenger (or other agent of the customer), it need not be counted under Reg D requirements." For clarification purposes, if an outgoing wire transfer is presented at the bank in person and the beneficiary of the wire is a third party, does the "third party" feature trump the "in person" transaction, making the transfer count in the Reg D limits?
11/27/2006
In regard to KYC and CIP, what personally identifiable information is the bank required to obtain for the beneficiary of an account? Full name, address, social security number and date of birth? We want to make sure that we are in compliance but a social security number and date of birth aren't always available for the beneficiary to the individual opening an account.
12/01/2005
Question: Our loan manager wants to introduce an incentive to anyone who purchases a home from a certain builder (one of our customers) and subsequently finances the home through o
03/21/2005
I have an Illinois UTMA account in my son's name. He turned 18 this year. Can I withdraw the funds for him and pay the taxes myself, as custodian? Am I able to close the account and be responsible for any taxes?