Vendor Guru Q&A - Compliance

What are the privacy issues related to having a contract person providing loan analysis as opposed to a full-time employee? This person would be required to see financial statements, credit reports, and other personal information about existing customers.

Strengthening Your Customer Information Policy & Procedures

01/20/2003

We have a policy and procedures on Safeguarding Customer Information. My problem is, FDIC EDP examiner wants more meat on it, such as; address logical and physical access controls to CIF. No incident response policies? I can't find the information in the Federal Register. Vendor oversight requirements have not been formalized, Can you direct me to any site that will have examples or answers to these questions?

Required Employee Training

02/11/2002

I'm a new compliance officer and I need to know what regulations require employee training. I'm in the process of putting together a compliance training calendar for my bank.

Surprises in the Final Information Security Guidelines

01/15/2001

The federal banking regulators have agreed to on final Interagency Guidelines Establishing Standards for Safeguarding Customer Information ("Guidelines"). You previously wrote two articles for us on the proposed guidelines. (See <a href="gurus_technology1211.html">Part 1</a> and <a href="gurus_technology1218.html">Part 2</a>.) Were there any surprises for you in the final version of Interagency Guidelines Establishing Standards for Safeguarding Customer Information? And could you give us a quick heads-up on what the final guidelines provide?

Processing Reg E Claims

10/13/2019

We were recently told that the way we process Reg E claims (and have been since before I was here and never had an audit issue besides wording of a letter) is backwards. Here are the few scenarios that will tell me which is right. It's September 2019: 1. If a customer comes in and says they haven’t balanced their statement for 5 years and just realized that $14.99 has been being debited from their account by Amazon since March 2016. Can you tell me what amounts or for what time periods they are owed and for which months/years? 2. If the same scenario happened but the first charge was on April 10th of this year? Can you tell me what they are owed and for which months? 3. Last, if the customer comes in and says that he is balancing his statements for the past two years and found several different charges that are fraud: a. A cable bill that debited for two months after he revoked authorization in 2018. b. Amazon Prime debited monthly for 12 months from June 2018 to May 2019 and he never agreed to it. c. GEICO debited his account $113.00 when he hadn’t authorized it to debit his account for that payment in August 2019.

How to Complete a CTR for an Estate

10/13/2019

How would I complete a CTR for an estate? The Trust Dept. opened deceased customer's safe deposit box and found $75,000 in cash. Funds were then deposited into a trust fund. I know the trust employee will be the transactor but how do we handle the "on behalf of"? Do we just put customer's name even though he is deceased? There's no where to put "The Estate of ..."

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