Would a student identification card be an appropriate ID for a minor account if they dont have a drivers license or state ID? The parent/guardian is on the account with them and we do have sufficient ID for them.
Is it a requirement to obtain photo ID's for Beneficial Owners who are not actually signers or responsible parties to a checking account or loan account? If not a requirement, is it overkill to obtain them?
I want to be sure we are correctly handling the annual report that needs to be made on compliance with the Red Flags rule. Two questions: Does the report have to be made to the Board of Directors and what is the content of the report.
marIt’s been about five years since we updated our Red Flags program. Do you think we’re still okay?
I have an issue that some of our tellers are not understanding. Tell me from the compliance standpoint of CIP how this should be handled. We have always required ID on all people, customersif you do not know them and noncustomersno question. However, some tellers are not asking for ID on noncustomers because they have been coming into the bank for the last 5 years to cash their check so they do not get their ID. How do you suggest we handle this situation?
I am seeking some guidance regarding the designation of exemption for a customer that mutually owns two businesses and conducts activity for both with our bank. He is a common owner listed on both accounts and therefore CTRs have been filed on both businesses on a single Currency Transaction Report by selecting the multiple persons and combining both businesses' aggregated transactions for reporting.The two businesses have separate accounts and tax ID numbers, the addresses and phone numbers listed are different as well. Transactions do not intermingle between the businesses and are clearly separated; the only common denominator is one of the principal owners of the businesses.When attempting to exempt the businesses can they both be combined under one Designation of Exemption? If not, only one of the businesses qualifies on its own to be exempt, would we be required to amend prior Currency Transaction Reports to separate the two businesses? Or have we been filing incorrectly to begin with?
Where does the responsibility stop for banks in determining a person's legal status? We know by looking at the SS Card its a fake but yet on Chex Systems and Credit Reports the SSN and Name of customer match up. How do we deny a person based on a fake ID when they've gotten away with it for so long? Do we have the obligation to police the legal status of a customer?
I just received two amended CTRs I had filed on 9.11.11 before they changed the rules for amended CTRS. At the time I attached a amended form with just the information that was incorrect on the original CTR. The rule changed on 10.31.11 stating that you made out a complete new CTR indicate it as amends prior report. So now it is 2013 and I have two CTRs to try to efile and can't find any instructions anywhere on how to do this. I tried to file FinCen CTR but it asks for a DOC # 14 numbers long; which of course I do not have. Do you have any idea where to find the documentation to show how to do this?
Where on the call report will I find the RSSD ID Number?
In a training last week it was brought to my attention on the new CTR form that it is requiring the ID collection of an entity. In the past this has never been the case and in the FFIEC manual it specifically refers to individuals. FinCEN has said that there is nothing new to the forms except the collection of the new fields. Not in any webinar or documents that we received from FinCEN said anything about identifying document collection of an entity for a CTR. The only thing I have seen regarding this is actually on the form from the help box in the ID field itself. Is this something we have to collect going forward?