Vendor Guru Q&A - Compliance

Latest Compliance - Know Your Customer Topics

Beneficial Owner Certification

08/09/2020

Regarding a Beneficial Owner Certification: ABC, LLC (Borrower) is 100% owned by DEF, Inc. DEF, Inc. is 33.33% owned by 3 individuals. Would I need to list the individuals as having 25% or more ownership on the certification, even though they are not owners of ABC, LLC?

Negative News Reports on Potential Customers

06/14/2020

Do you have any recommendations on sites that offer negative news searches where you can find negative news reports on potential customers - or a list of sites you recommend.

Updated ID for Existing Customer for New Acct?

05/31/2020

Are we required to get an updated photo ID on an existing customer when we open a new account relationship with them (i.e. a loan, DDA, savings, etc)?

FinCEN Beneficial Owner Form

06/17/2018

Is there a form template for tracking an entity’s beneficial owners?

Reporting on Related Entities

06/03/2018

How do other banks build related entity reports?

CIP Requirements for Opening Acct. Under FLUTMA

03/18/2018

My inquiry has to do with CIP requirements regarding opening an account under a FLUTMA (we are in Florida). The account holder which is the grandmother opened an account under a FLUTMA for the grandchild. The parents do not wish to release a copy of their child's birth certificate due to possible fears of compromise. Is it mandatory to require CIP information on the minor once the Chex Systems clearance has been obtained; is a birth certificate actually required?

Legal Requirements for a Signature Card

03/19/2012

What are the legal requirements for a bank to open a savings account for an individual customer? From what I understand, banks usually require (1) a signature card and (2) the following identity information: name, address, date of birth and identification number. I don't need any clarification on the identity requirements for Know Your Customer compliance. I am looking for more clarification on the requirements for the signature card. Is the signature card required by law to open a bank deposit account? If so, what is the law and what is the legal definition of a signature card (e.g. the required elements for a signature card)?

Managing BSA: Essential Program Elements

08/01/2004

One of the best sessions at ABA's National Regulatory Conference was presented by John Atkinson, with the Federal Reserve Bank of Atlanta and Pam Johnson, Director with Deutsche Bank Trust Company.

KYC vs. CIP

12/01/2003

Question: In training sessions, staff has asked me what the difference is between the old Know Your Customer standard and the new Customer Identification Program and why we have to

Why CIP?

06/01/2003

The business of banking has just received yet another compliance requirement: the Customer Identification Program. The new CIP isn't really new.

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Safety & Security Coordinators: The Untapped Resource

The Bank Protection Act of 1968 requires annual robbery training, the Bank Secrecy Act has a training requirement for Suspicious Activity Reports, and there are several other regulations around cus

Opening an Account for a Non-US Citizen

Question: We are a small bank, in a small town, and pretty much know all of our depositors.

Escrowing during Construction

10/25/2020

Can we collect property taxes during construction based on the completed value of the home?

Reg E Question About Credit Card Fraud

10/25/2020

When a cardholder has a fraud alert on their card and they tell the fraud center that the transactions are NOT fraud, the fraud center reopens the card. Now the customer has roughly 10 or more charges from the same company that she just said were not fraud. Now she is claiming that they are all fraud. (including the original charges) What do we do?

Chamber of Commerce Cash & Prize Giveaway

10/25/2020

Our Chamber of Commerce is hosting a cash & prize giveaway to encourage people to shop local during the holidays. As a member of the Chamber of Commerce, the bank has been asked to pass out tickets as entries to win. Each business has a limited number of tickets. Employees of the bank are not allowed to obtain any tickets from the bank, but can from other businesses participating. My question is, can we offer multiple tickets as incentives for our customers to use other services we offer? Examples would be: 1) A customer comes in to make a deposit= 1 ticket. If they sign up for online banking while here we will offer an additional ticket. 2) A non customer comes in to cash a check= 1 ticket. If they open an account with us we will offer additional tickets. 3) A customer asks about a home loan= 1 ticket. If they qualify, they can earn additional tickets. If they decide to finance with us more tickets.

Misleading Collection Scripts Cost Financial Institution $28.5 Million

10/18/2020

In its $28.5 million settlement with Navy Federal Credit Union (NFCU), the Consumer Financial Protection Bureau (CFPB) stated that NFCU's collection letters contained material misrepresentations – or unfair or deceptive abusive acts or practices – that were likely to mislead consumers; how did NFCU's templates violate UDAAP?

Add Bank Fees Paid in Cash to CTR?

10/18/2020

Should bank fees (Cashier Check purchase fee of $6.00) paid by the customer in cash, be added to their current CTR? If so, would the bank be the benefactor and the customer the transactor?

Latest Compliance - Know Your Customer Topics

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