Please clarify if the following transaction would be considered a refinance or a purchase. We have a newly elected Director on our board. His home loan was approved before he became a director. After he was appointed to the board, his home loan was modified. Should this have come before the board to obtain approval?
The chairman of our Board of Directors is buying a house. Can we waive the 1% origination fee without being in violation of Reg O? We do on occasion waive this fee for other customers in order to compete for a loan.
I've been told that when 100% of a bank stock is issued by a holding company and it is not publicly traded, the reporting requirements under section 215.10 of Reg O do not apply should an executive officer or director pledge the bancshares as collateral for a loan at another financial institution. I cannot substantiate this claim. Have you ever heard of this?
We are having a misunderstanding at my financial institution about the USA PATRIOT Act. We were first opening corporate accounts and gathering identification documentation and social security numbers on all the signers on corporate accounts. We were then instructed that it was unnecessary to obtain this information on the signers. Then about a year later we were instructed that the USA PATRIOT Act does require us to get this information. Does BSA or the PATRIOT Act require financial institutions to get ID for signers on corporate accounts as of 2007? If it does not, where can I find this information?
I have been newly appointed to a bank Board of Directors and have little banking knowledge. I have been approached by one of our tellers with a concern about CTRs. It seems that on a regular basis (couple times a month) a customer comes into the bank with two checks around $6500.00 each and has them cashed. One is in his name the other is in his father’s name. Each time he is alone and walks out of the bank with around $13,500.00 cash. My teller is afraid that this is a BSA violation. Is this a violation? Would this at least warrant a Suspicious Activity Report?
What are the bank policies that need board approval and how frequently?
Should the BSA Officer report directly to the board of directors?
We are a savings mutual association, a member of SAIF and insured by the FDIC. What are we required to have in advertisements for deposit products concerning FDIC insurance? What do banks have to have?
Does the Bank Secrecy Officer have to be a senior level officer at the bank? What section of the regulation covers this?
Regarding Regulation O Section 215.9, relating to Executive Officer reporting loans from other "Banks." Does this definition of Banks mean only members of the Federal Reserve? We are regulated by OCC and I looked in their Insider Activities handbook, but it only states 215.9 Reports by Executive Officers "Executive officers must provide a written report to the board of directors within 10 days of becoming indebted to any bank if the aggregate amount of the indebtedness exceeds $100,000 (or the greater of 2.5 percent of the bank's capital and surplus or $25,000). The report shall state the lender's name, the date and the amount, security, and purpose for each extension of credit."