Vendor Guru Q&A - Compliance

Collecting Updated Tax Returns

Latest Compliance - Board of Directors Topics

What does my regulator's request mean?

10/30/2016

What does our regulator mean by "most recent report for SAR /CTR filed along with 3 years filing trend"?

Who do we have to train on BSA and how often?

07/03/2016

Who do we have to train on BSA and how often?

"Checklist" to Use in Compliance

12/12/2015

Is there a "checklist" to use in compliance that would list the things for each regulation that need to be completed each year? For example, annual training, reports required board notifications, etc.

Corp Board Appoint New Signer if Only One Deceased

01/07/2013

If there is only one signer on a corporate account and he passes away, can the corporation's board of directors appoint a new signer?

Business Purpose Medical Marijuana-Legal?

10/08/2012

I have a possible prospect that would like to open a business account here and he has his business license and EIN number. The purpose of the business is Medical-marijuana dispensaries. We are a community bank and I want to know if it is legal to even open in the state of WA. I understand it is legal to have these dispensaries in the state of WA, will we be in compliance?

Board/Executive Officers Exempt from OD Safeguard?

06/18/2012

Are board of directors and executive officers exempt from having Overdraft safeguard? What if they are listed in a non-owner relationship in a deposit account?

Waiving Overdraft Fees for Board of Directors

09/12/2011

During our annual internal audit of Reg. O, we discovered that overdraft fees are being waived for the board of directors. The overdrafts were under $1,000 and the account was not consecutively overdrawn for 5 days or more. At first, we felt that we could defend this by proving that our BOD is in similar circumstances as other depositors that we waive overdraft fees for. Management has decided that proving these "similar circumstances" may not be a risk we want to take with examiners. How should we handle this violation? Should we have the board members that are in violation pay the fees that were waived? Or should we implement training and awareness to ensure this violation does not happen again?

Extended Due Date on Loan for Director (Reg O)

08/29/2011

A director (reg o) has a loan. Can the due date be extended each year without board approval with the same interest rate? This loan started in 2007 and each year the due date has been changed for another year. The loan is an unsecured loan for 25,000. Also, this director has another unsecured loan for 5,000 with the same thing happening.

Printable Guidelines for Cashing Business Checks

08/15/2011

I have a customer who is the sole member of a corporation. He has been told by his attorney and accountant that he can cash a check made payable to the corporation. This is not our bank's practice. Can you direct me to something printable to give to my customer stating guidelines for cashing business checks?

Responsibilities for In-House Auditor?

04/25/2011

What are the responsibilities for an In-House Auditor? Our auditor considers daily activity of the employees as an auditor responsibility.

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UDAAP: The CFPB’s First Case

In its first significant enforcement action, the Consumer Financial Protection Bureau has issued a consent order against Capital One Bank.

BSA Enforcement Hits Royal Bank of Scotland

As many foreign banks doing business in the United States have discovered, it is not enough to import the compliance systems used in the home country. When in the USA, do as the USA requires.

When to File CTR for Reg E Dispute Over $10,000

05/20/2018

At what point would a CTR be filed for a Reg E dispute claim which states that over $10,000 in cash was deposited in the ATM? At the time a provisional credit is posted to the customer's account or at the time the Bank decides to make the provisional credit permanent, which could be 45 days? What business date is then used for the CTR, date of deposit in the ATM, provisional credit date, or permanency decision date?

Stop Payment On ACH Item End After 6 months?

05/20/2018

Does a stop payment on an ACH item end after 6 months?

Reg DD Disclosures for Negotiated Rate? (APY)

05/20/2018

Are Reg DD disclosures, especially the APY required when, for example, a customer negotiates a bumped up rate for 3 months?

New Money Market Account After Changed to DDA?

05/20/2018

If I customer has exceeded Reg D limits on a Money Market account 3 times within the past 12 months, and the account has been changed to a regular DDA, can they open a new Money Market DDA with a different account number?

Can we offer a prize to everyone, for charity?

05/20/2018

We have a “spin the wheel” promotion. To spin, a customer must donate $1 that the bank donates to a charity. All the prize amounts on the wheel are more than $1 therefore all customers will get more than they donate. The amount won is then sent to the customer via our e-wallet app. We set a certain number of spins and it is done on a first-come-first-served basis.

Latest Compliance - Board of Directors Topics

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