Vendor Guru Q&A - Compliance

Latest Compliance - BSA Topics

Monetary Instruments Log for Credit Union

08/09/2020

I am trying to create a monetary instruments log for our credit union. I have not been able to find a list of the required information needed on the log. Where can I find that information?

Back-office Document Imaging

06/21/2020

What types of back-office documents do banks image and store electronically?

CTR for Large Check for Christmas Bonuses

01/19/2020

A customer cashes a large check that results in a reportable CTR. My question is that the funds from the check are for Christmas bonuses for the customer's employees. I have the customer as the conductor, but who will be the beneficiary? Can we list the business as the beneficiary?

International Addresses and Online Payments

12/01/2019

We have learned that if a customer has an address outside of the U.S. they cannot use the bill pay feature of our internet banking program. Once their address is changed to a U.S. address they do have access to bill pay. Is this a requirement due to a U.S. banking regulation regarding persons with international addresses and online payments? Or is this simply a voluntary security feature of our online banking vendor?

How to Complete a CTR for an Estate

10/13/2019

How would I complete a CTR for an estate? The Trust Dept. opened deceased customer's safe deposit box and found $75,000 in cash. Funds were then deposited into a trust fund. I know the trust employee will be the transactor but how do we handle the "on behalf of"? Do we just put customer's name even though he is deceased? There's no where to put "The Estate of ..."

Revenue Derive from Marijuana Related Activity?

12/16/2018

Does due diligence require asking 'Does this revenue derive from marijuana related activity?'

Patriot Act Notices/UBO Notices on Bank Website?

09/09/2018

Do Patriot Act Notices and UBO notices have to be on the bank website? We do not open accounts online at this time.

SAR Document Management

06/24/2018

Can copies of SARs be maintained in electronic format?

Are IOLTAs in for beneficial ownership?

04/01/2018

What is a legal entity?

Asking What Cash is Being Used For (Over $5,000)

03/04/2018

Our BSA officer insists when a customer deposits or withdrawals over $5,000 in cash, we have to ask what the cash is being used for. Is there regulation to support this? I understand CDD, but isn't this taking it too far? Is it our job to be nosey?

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Expiring Individual Taxpayer Identification Numbers (ITINs)

by Patti Joyner Blenden

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.

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?

How to Complete a CTR for Local Diocese

10/18/2020

A question came up during a recent audit in regards to how a CTR would be completed for a local Diocese. This particular Diocese has a few different churches using the same EIN. Our system recognizes large currency transactions that we compare to see if a CTR was completed. My question is, would a CTR be filed on that specific church when deposits of cash are over $10k, or on the Diocese?

Latest Compliance - BSA Topics

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