Is it required for a bank to have a policy regarding posting of job openings on Facebook?
Our Bank policy is not to pay probationary employees for holiday pay, citing this as an employee benefit, which probationary employees are not entitled to. I believe this is not correct and that these employees should be paid. Can you help me with this issue?
Does BSA training have to be done on an annual basis?
An employee of the loan department received her real estate license without consultation or approval from Management. The licensing status is currently active. We understand there are implications regarding conflicts of interest, HR policy issues, and independence issues related to any duties associated with real estate lending. However, there are two questions related RESPA and Reg Z.
Question 1.- Does sharing an employee with a real estate agency now constitute an affiliated business relationship requiring the Affiliated Business Disclosure?
Question 2. How does this impact calculations of points and fees for HOEPA loans? Do we include commissions into the point and fee calculations based on them being paid to a third party?
What is required for vacations by the FDIC?
What is a "security committee"? We already have BSA, Compliance, Human Resources, Audit and Executive Committees.
I plan to include a recommendation in my annual report to change the current reporting structure for the Security Officer. Presently, I report to the VP of Retail Operations. I am seeking references to cite that advise the bank security reporting structure should be in other areas such a finance, risk, administration, but not through retail because of the apparent potential for downward influences and the need for independence.
On July 30, 2002 the Sarbanes-Oxley Act (SOX) was signed into law.
The role of the financial institution's Security Officer is different from any other industry. Banking is the most regulated industry in the United States.