A corporate customer's account was recently compromised. Information from an authentic check was used to create fictitious checks. Numerous $100 checks were negotiated. The fake checks don't include a payee name. In addition, the checks don't have any type of endorsement. If we consider these checks bearer instruments, and no endorsement is required by UCC, do we have any recourse with the institution who processed the (fictitious) checks, or is the loss on our side since the customer failed to identify the fake checks in time for a timely return?
Regarding OFAC compliance, should my 314a scans of wire activity include both domestic and international wires or just foreign wires sent or received?
For police reports, if the bank is taking the loss on large dollar amount claims, can the bank file a police report?
Is use of a general AAN turndown reason such as: “Unqualified co-applicant” considered specific enough for Reg. B compliance or should a general turndown reason like this be avoided?
Now that banks can participate in lotteries, can we facilitate raffles unrelated to the bank for local service groups- post lobby posters or sell tickets for or be a sponsor, etc.?