Vendor Guru Q&A - Compliance

Latest Compliance - Board of Directors Topics

Are Board of Director Committees Required?

12/15/2019

Are Board of Director committees required per regulation and if so, which ones? If not, what types of board committees are typically held by a financial institution?

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?

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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.

Escrowing during Construction

10/25/2020

Can we collect property taxes during construction based on the completed value of the home?

Reg E Question About Credit Card Fraud

10/25/2020

When a cardholder has a fraud alert on their card and they tell the fraud center that the transactions are NOT fraud, the fraud center reopens the card. Now the customer has roughly 10 or more charges from the same company that she just said were not fraud. Now she is claiming that they are all fraud. (including the original charges) What do we do?

Chamber of Commerce Cash & Prize Giveaway

10/25/2020

Our Chamber of Commerce is hosting a cash & prize giveaway to encourage people to shop local during the holidays. As a member of the Chamber of Commerce, the bank has been asked to pass out tickets as entries to win. Each business has a limited number of tickets. Employees of the bank are not allowed to obtain any tickets from the bank, but can from other businesses participating. My question is, can we offer multiple tickets as incentives for our customers to use other services we offer? Examples would be: 1) A customer comes in to make a deposit= 1 ticket. If they sign up for online banking while here we will offer an additional ticket. 2) A non customer comes in to cash a check= 1 ticket. If they open an account with us we will offer additional tickets. 3) A customer asks about a home loan= 1 ticket. If they qualify, they can earn additional tickets. If they decide to finance with us more tickets.

Misleading Collection Scripts Cost Financial Institution $28.5 Million

10/18/2020

In its $28.5 million settlement with Navy Federal Credit Union (NFCU), the Consumer Financial Protection Bureau (CFPB) stated that NFCU's collection letters contained material misrepresentations – or unfair or deceptive abusive acts or practices – that were likely to mislead consumers; how did NFCU's templates violate UDAAP?

Add Bank Fees Paid in Cash to CTR?

10/18/2020

Should bank fees (Cashier Check purchase fee of $6.00) paid by the customer in cash, be added to their current CTR? If so, would the bank be the benefactor and the customer the transactor?

Latest Compliance - Board of Directors Topics

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