Our examiners made the bank change customers passwords to expire on online banking every 60 days. Of course, customers do not like this. Can you tell me what the requirements are on this?
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?
Would a trust be considered a legal entity or natural person when it comes to Truth in Lending, RESPA, and HMDA disclosures?
Since the NMLSRs inception, different banks have referred to an MLOs unique identifier differently. Would you please settle this question? Is it an NMLS number, an NMLSR number, or an MLO number? Does it matter?
According to Reg CC is the exception hold placed on the entire deposit or can the hold be placed on a specific check within that deposit? Where in the Reg do I find this answer?
CIP grandfathered customer (prior to 10/1/03). Customer has a PO Box listed, no physical address. Do we need to obtain physical address now that we have identified the PO Box exception?
I overheard an employee recommending to a customer to deposit part of a deposit one day and the rest of the money the next day, therefore avoiding the filing of a CTR. What action would need to be taken on this employee? I need to make sure that all the bases are covered and all the reports needing filed are filed.
Since trust documents can be very long, which pages should be required for a deposit account? Typically, we take first page that lists Title of trust, date of trust, who trustees are, successor trustees, financial part and signatures of owner. Do we need the financial part?
When an originator takes a phone application, what is acceptable by the regulators that all the proper disclosures have been provided to applicant? My other concern is can we still pull a credit report with written authorization from applicant? ( This usually being provided by a signed application.) I was and still am under the impression that credit should not be pulled until you have an application.
How does Reg E apply to a Business? We are thinking about offering debit cards to our business customers. Does Reg E only apply to consumers regarding the liability and chargeback rights on debit cards?