Most Popular Compliance Content
Handling Deposits of MRB Staff
03/26/2023
A dispensary (Marijuana Related Business) just opened this month in town. We have two members (we are a credit union) that receive payroll from there (ACH). - Given their employer, is it illegal for them to bank with us? - Do we need to terminate our relationship with them? Our policy only states for MRB's that we would allow tier 2 and 3. Technically it is an individual, not a business though. Are we allowed to keep them? I know there are SARs we may have to file for MRB's (limited/terminated, etc.). If we keep thee depositors, do we have to file a SAR every 90 days on the individuals as long as they are employed at the dispensary? We understand there is a certain risk having them. There is really no guidance from FinCEN regarding employees of MRB's, just MRB's themselves. Any guidance would be greatly appreciated.
UDAP vs. UDAAP
03/26/2023
Where does the CFPB’s authority come in when they determine something is “Abusive”?
What is “Abusive,” technically?
03/19/2023
In terms of UDAAP, what makes something “Abusive”?
Using ASMs Alerts for High-Risk Reviews
03/19/2023
Can I solely rely on alerts from my automated surveillance monitoring system to conduct my high-risk reviews?
Check Return Timeline
03/19/2023
I wanted to reach out in regards to time frames that depositing banks have to respond to a check return. As with most other banks, I’m sure, we have seen an increase over the last 2 years of check fraud alternating between both altered checks and endorsement fraud. We typically try and return the item and collect for our customers the lossed funds, but most of the time our returns are denied as they are a late return. The denials that we receive though range from 2 weeks – 3 months so I wanted to reach out to see if there is a time frame that a depositing bank has to deny a returned check so we know on our end as far as giving our customers final credit for the check return?