We are a de novo bank and our BSA officer mentioned that it was "recommended" by FDIC regulators that banks need to check their correspondent banks on OFAC anytime they send or receive a wire from them. To me this seems pointless and quite excessive. We send/receive wires through PCBB and I can't see us needing to check OFAC lists for their name daily. Is this really necessary?
For the Reg CC RDC indemnity, it states; "(2) A bank described in paragraph (f)(1) of this section shall indemnify, as set forth in § 229.34(i), a depositary bank that accepts the original check for deposit for losses incurred by that depositary bank if the loss is due to the check having already been paid." We have a customer which is a business offering check cashing and it makes deposits via remote deposit capture. I am confused over the liability and timing of paper vs. electronic deposits, duplicate items and will restrictive endorsements influence liability?
A ninety-seven year old widowed customer was brought in by one of his sons to change the register on his account. Our customer's wife had passed and he removed her and added the son as beneficiary to his now sole ownership account. Six months later the same son was granted Conservatorship over his father and changed the register to "Estate of..." Should we leave the beneficiary on an Estate of Conservatorship account?
An IRS levy requires payment after 21 days. - When the 21st day is on a non-business date, when should the funds be sent? - Are the 21 days calendar days? I have found no information in the IRS codes addressing the details of 21 days.
The NCUA has a regulation that will not allow a federal Credit Union to close out a member's relationship without being approved by the NCUA Board. However, the FFIEC manual allows for an institution to close out a member due to multiple SARs. Does the FFIEC Regulation supersede the NCUA regulation that requires approval before closing out a relationship?