Vendor Guru Q&A - Compliance

Latest Compliance - Know Your Customer Topics

Beneficial Ownership information on Loan Guarantor

02/07/2021

Is it a requirement to gather Beneficial Ownership information on loan guarantors?

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

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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.

Church/Credit Union: Non-government Organizations?

08/01/2021

We are going back and forth as to whether or not a credit union or a church are actually considered non-government organizations? Although we know that they are non-profit, I have read conflicting information and am trying to settle this internally.

Record Retention for Debit Card Dispute Docs

08/01/2021

How long do we need to keep debit card dispute docs? (What is the time of retention?)

Advertising-more than ECOA, TILA, TISA and Fair Housing

08/01/2021

Is following the standard Regs, B, Z, DD and fair housing going to ensure advertising compliance?

Handling Reg E claims on older transactions.

07/25/2021

If an EFT claim is made long after the statement is sent showing the transaction, the rules of investigation don't apply. So why do we investigate any of these claims?

Compliance Info on Paper Checks

07/25/2021

I was wondering if you could point me in the right direction as to where to find more information on compliance for paper checks? Whenever I place a stop payment on a paper check, there's a disclosure that says "this request will expire in 6 months in order to comply with regulatory requirements." For the customers who ask for a more in-depth answer, what can I tell them?

Latest Compliance - Know Your Customer Topics

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