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?
Is there a rule or regulation that requires banks to make their online banking customers change their online banking password periodically?
When the owner of an HSA passes away and there is a signer left, does the HSA need to be frozen or closed, or does the signer get to continue using it?
We have a business customer that mailed a check to a business for payment, and that payee is claiming they never got the payment. We can see the check cleared our customer's account in February 2018. We feel it could have been intercepted by a third party and negotiated. The BOFD did confirm that the check was negotiated at their institution, but obviously can not confirm who the third party is, or if it is in fact a third party. Do we have any recourse on this? We were thinking a warranty claim but do not have much experience with this or where to find those forms.