Can we put a cap on how much may be added to a time account after the initial funding? For example, if a customer opens a time deposit with $5,000 and then wants to add $100,000, we would not allow that. Can we put a restriction in place that you could not add more to the account during the term than the original amount, so if the account was opened with $5,000 that they could not add more than an additional $5,000? Also can we allow an HSA CD to be a time account, or are there restrictions on this?
What are the requirements in relation to counseling reports for excessive overdrawn accounts and what regulation can I find that in? We already send notification out each time an account is overdrawn more than 6 times in a 12 month period. We also contact customers via phone and letters at 15, 30, and 45 days of being overdrawn. Are we required to mention "counseling?"
We need to do a CTR for an ITF account because the custodian came in and withdrew over $10K. For filing guidance we see examples of deposits, but not of withdrawals. Should the beneficiary of the trust be on the CTR assuming that funds withdrawn were for them? All we know is that the beneficiary walked out with the money. Also, should "ITF" be shown on the CTR anywhere?
Can an account that is set up in a trust have a beneficiary listed on the account?
Any idea how long we need to retain a "referral authorization" that we have between a collection agency and our customer?