10/18/2010
The bank wants to give a gift under $25 for all customers who fill out applications for credit cards or loans. This promotion will be held at branches in certain areas, but not statewide. Flyers will be available at all the personal bankers' desks. What would be the compliance requirement?
09/27/2010
Where is it stated that Reg CC does not apply to foreign checks? Example: checks drawn on a Canadian bank should be sent for collection and that a Reg CC hold does not apply in this situation. I can not seem to find this in any material.
07/19/2010
Do banks still have to maintain a CRA file? The statement is posted in main lobby and branch. If we need to have a file, what do we to have in it?
04/06/2009
When opening deposit accounts, our bank uses a minimum Beacon. Our system will automatically decline the account or the individual signer if their Beacon score is below our set minimum. We would then provide the appropriate adverse action notice. Our branches seem to think that everyone who has a Beacon Score above our minimum is automatically guaranteed a checking account regardless of any other factors. I know that if we use anything on that credit bureau report to make our decision we will have to give an adverse action notice, but can't we still use factors over and above the minimum score?
02/23/2009
I am trying to find a CRA public file checklist for branches. Where I can find a list of what needs to be included on a branch level?
11/24/2008
Our grocery store branches have limited floor space. During the day they can move some signs to the walkway in front of the branch and at night, pull them back in before the gate is lowered. For ease of use and to vary the product offerings they are using whiteboards and people with really nice penmanship. What compliance problems are there with whiteboards?
03/24/2008
What disclosures are required for changing a branch's hours? Specifically having one branch not open on Saturday when only the drive through was open so it's not a banking day for Reg CC.
12/17/2007
What is required in a large bank CRA public file?
06/04/2007
One of our branches has a customer (a builder) writing large checks to their employees on a weekly basis ($5k-$7k). The builder comes in with the employee to cash the check. The employee endorses first, then the builder endorses and cashes the check. The builder is a known customer, so the tellers do not get identification on him and since he endorses after the payee they are not getting the payee's identification. They are, however, checking the payee/employee against OFAC. Bank policy states that we check OFAC on all non-customer payees over $1000 and record identification on non-customers and payees over $3000. I am getting a match on two of the three employees. I am 90% sure that it is a false positive, but I cannot confirm or deny it is a valid hit unless I can compare their identification information to the hit. The branches administrator was notified that the branch is not following bank policy and that identification needs to be obtained on the payees. The branch defends their actions stating that, technically, they are not making an exception since the employee and builder are presenting on-us checks we are able to verify funds and also that the last endorser is vouching for the non-customer. I understand their concern because it is technically true, but as the Compliance Officer I also understand that, per OFAC, banks must block transactions that are by or on behalf of a blocked individual or entity. If this branch continues to willfully ignore the intent of the customer, which is to give money to this employee, we will end up with severe penalties if the payee is found to be a blocked individual. This is a risk I would rather the bank not take. Can you shed some light on the subject?
05/07/2007
I am an auditor of a bank and did the branch audit yesterday. What are the requirements under CRA for the notice to be posted in a branch of a bank which is OTS regulated? I have a copy of the notice and want to make sure that it complies with the Reg.