We have a “spin the wheel” promotion. To spin, a customer must donate $1 that the bank donates to a charity. All the prize amounts on the wheel are more than $1 therefore all customers will get more than they donate. The amount won is then sent to the customer via our e-wallet app. We set a certain number of spins and it is done on a first-come-first-served basis.
Will the $100 next-day availability rule be updated?
Our private banking area is requesting to add two higher balance tiers on an investment savings account. There is no regulation or rule that would hinder this correct? The only thing I can see is if we are not offering this to other bank customers, but only to these high end customers.
I am seeking some advise on BSA regulations around aggregation of secondary account holder. Is it a requirement by FinCEN to aggregate transactions based on secondary relationship between accounts and file a CTR? Example: Joint account relationship Account (A) - Chris (P) / Joe (S) Account (B) - Joe (P) / Brian(S) Chris as a conductor makes 6K Deposit into Act A at Branch X Later, Joe as a conductor makes 5K Deposit into Act B at Branch Y should a CTR be filed considering Joe has secondary relationship with Chris in Account A and ultimately benefits from the deposit made?
Does the $1,000,000 business loan threshold for evaluations apply to farmland?