08/13/2023
If a credit union allows a member to establish a new transaction account after they pay back the amount owed from a closed, charged off account, would the newly established account be subject to Reg CC's new account definition? This would mean applicable checks deposited into that account to would be subject to new account holds.
Could we determine that the member's actions causing the the charge-off means they forfeit the benefit of the previous account for Reg CC, and this newly opened account would be a "new account" holds under Reg CC, or would this be a misapplication of Reg CC's new account exception?
07/30/2023
For corporate accounts, can anyone other than the Secretary sign a Signature Card resolution? The Secretary is not always available to sign and I'm curious if another officer of the corporation can sign?
04/09/2023
I was recently told that Rep Payees for veterans specifically, were restricted from having transfer capability via an online banking profile. Is that correct, and if so, when did that go into effect and where is that rule?
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.
10/23/2022
Can an estate account be opened in a different state from the one the decedent resided in? We have an executor who lives in our state, but the decedent is from a different state. The executor would like to open an account with us after she was told by larger regional banks that they would not open an estate account if the decedent and executor did not live in that same state.
10/02/2022
This is actually Texas specific, but I need help. Does the Uniform Single- Or Multiple-Party Account
Form apply to sole proprietorship accounts? I cannot find a clear answer on the applicability to this account or entity type.
07/03/2022
Can a bank account be opened for a non-US citizen who is here to work for 2 months with an ITIN number rather than a work purpose only Social Security Number?
04/24/2022
What is the regulation and where do I find this, on holding bank statements for customers, or is it a bank policy issue?
04/17/2022
I am reviewing a deposit ad for branch flyers. The Free Banking Service package includes an array of free services including free money orders, official checks, and stop payments. Should there be a disclosure as to how many and how often the customer can receive this benefit or does the statement to contact an employee for more information cover this?
04/10/2022
What happens when one of 2 or more beneficiaries dies before the account owner? In this case I'm referring to a depsoit with two beneficiaries and one has pre-deceased the account owner. The account is in PA if that influences the answer.