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.
In regards to the check box options on an adverse action notice, as a commercial lender, I would like to add “Length of time in business is too short” as we do deny credit to many newly established companies (per our credit policy). So my question is this: Can I create my own reason or is there a specific set of reasons that I need to adhere to? Where does ‘length of time in business too short’ or verbiage to that effect fit on an adverse action notice?