Vendor Guru Q&A - Compliance

Latest Compliance - Fiduciary Topics

Include Custodian on CTR? (UTMA)

09/24/2017

Is a custodian of a minor's account considered a person on whose behalf a reportable transaction is completed on a CTR? We have a situation where someone came in and deposited over $10,000 into the minor's account. The conductor is neither the minor or the custodian. I know that we have to include the conductor and the minor on the CTR. But do we have to include the custodian?

Benefiting Client's Info On CTR (IOLTA)

08/16/2015

When filing a CTR on an IOLTA account, do I need to include the benefiting client's information on the CTR if the Client is incapacitated?

Can Conservator Request Info Pre-Date Appoint?

02/03/2014

Can a conservator request information pre-dating their appointment?

Transfer from IRA to Atty IOLTA for Investment?

04/08/2013

Should our trust dept allow transfer from a self directed IRA to an attorney's IOLTA account for an investment when there is no fiduciary relationship with the attorney?

Conservator Sign Doc on Behalf of Protected Person

03/18/2013

How does a conservator need to sign documents on behalf of a protected person? Do they need to sign their name and title or just their name?

Federal Levy Against Special Needs Trust

01/28/2013

We have a client who has a special needs trust, of which we are the trustees. We were served a federal levy against the SNT. Should this be allowed?

Account w/ One Person as both A-i-F and POD

12/05/2011

Can a person signing as an A-i-F on an account be added as a POD beneficiary on the same account?

Custodian Direct Deposit into ILUTMA Account?

02/14/2011

On ILUTMA accounts, can the custodian have their paycheck direct deposited into the account?

Cashing Check for Beneficiary of Rep Payee Account

02/07/2011

We have a representative payee account where the representative will sign a blank check drawn on the representative payee account and then give it to the beneficiary, who will then come into the bank and cash it. Are we ok to give a balance to the beneficiary and are we ok in cashing a for the beneficiary?

Filing a CTR for a Custodial Account

01/10/2011

We had a customer come in and make a deposit over 10K to a custodial account on which she is not a signer. Whose information do we place in Section A of the CTR: the custodian's or the minor's?

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Church/Credit Union: Non-government Organizations?

08/01/2021

We are going back and forth as to whether or not a credit union or a church are actually considered non-government organizations? Although we know that they are non-profit, I have read conflicting information and am trying to settle this internally.

Record Retention for Debit Card Dispute Docs

08/01/2021

How long do we need to keep debit card dispute docs? (What is the time of retention?)

Advertising-more than ECOA, TILA, TISA and Fair Housing

08/01/2021

Is following the standard Regs, B, Z, DD and fair housing going to ensure advertising compliance?

Handling Reg E claims on older transactions.

07/25/2021

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?

Compliance Info on Paper Checks

07/25/2021

I was wondering if you could point me in the right direction as to where to find more information on compliance for paper checks? Whenever I place a stop payment on a paper check, there's a disclosure that says "this request will expire in 6 months in order to comply with regulatory requirements." For the customers who ask for a more in-depth answer, what can I tell them?

Latest Compliance - Fiduciary Topics

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