We have a not for profit hospital in our area. I have checked the local property taxes and they do not receive any of those funds and being a not for profit, I do not think they are federally funded. Would these funds be considered public funds?
What’s the official word as to why FinCEN is issuing the rule?
How often do most banks perform deposit compliance audits and is there any preference among examiners as to frequency?
It appears we are going to be starting from scratch in developing the new CDD 5th Pillar language that must be added to our policy. Any thoughts on how to proceed?
Which parties within the bank receive the audit report and which receive the compliance monitoring report?
Is there any where in Reg CC that states the bank can hold a check for the entire amount for a New Account?
If an EFT claim is made long after the statement is sent showing the transaction, the rules of investigation don't apply. So why do we investigate any of these claims?
If you use a vendor that provides credit scores from all 3 bureaus and you only use the score/reasons from one bureau for the denial, do you use that specific bureau's name and address or the actual vendor that supplied the report for your adverse action notice?
What is your view on retention of the physical deposit hold notices to meet Reg CC retention requirements? We recently converted our core system and have the opportunity to electronically record data used to populate deposit hold notices rather than retaining the physical forms.The data will be in the form of a report rather than a customer view of the notice. Parameters are set in the system for hold types, hold days, and makes consideration for multiple hold scenarios such as large deposit hold for amount over $5,000, two day availability for $4,800, and next day for $200.There is also a required field for facts to support reasonable cause holds when confidential information is selected.
I would like to know what (if any) parameters surround banks giving bonuses to customers. I am familiar with the typical $10 refer a friend program but I am looking at amounts exceeding $10,000 on more than one occasion. The bonus or referral fee (I’m not sure how it is categorized) is paid based on how many people sign up for pre-paid cards on a monthly basis. I was able to find this article (noted below) but I think it misses the mark regarding what I’m looking for. The reason why I saved this article was
the bonus payments I’m referring to do not fall within the guidelines of numbers 1-3. “Now let’s look specifically at Regulation Q and what it has to say about paying a bonus on an account. In fact, §217.101 is specifically titled “Premiums on Deposits.” (a) Section 19(i) of the Federal Reserve Act and 217.3 of Regulation Q prohibits a member bank from paying interest on a demand deposit. Premiums, whether in the form of merchandise, credit, or cash, given by a member bank to a depositor will be regarded as an advertising or promotional expense rather than a payment of interest if: (1) The premium is given to a depositor only at the time of the opening of a new account or an addition to an existing account; (2) No more than two premiums per account are given within a 12–month period; and (3) The value of the premium or, in the case, of articles of merchandise, the total cost (including taxes, shipping, warehousing, packaging, and handling costs) does not exceed $10 for deposits of less than $5,000 or $20 for deposits of $5,000 or more. “