Most Popular Compliance Content
Trust Agreement Need to be Signed/Notarized?
10/13/2019
We have a business organized as a trust that is opening an checking account for a bingo unit. There is only one person named in the Trust Agreement. His name is Mike. Mike is named as a trustee/designated agent in the Trust Agreement. He is wanting to add his bookkeeper, Kim, to be an agent on the account. Is this allowed for trust accounts, or are only people designated in the Trust Agreement allowed to be on the account? Also, the Trust Agreement is not signed or notarized, which raised some questions for our New Accounts Rep. Does the Trust Agreement need to be signed and/or notarized?
Website Change Management
10/13/2019
We currently keep both electronic copies and paper copies of every change made on our website. This is time-consuming to maintain. How critical is it to keep hard copies of our work, and what questions should we be asking ourselves to potentially reduce or eliminate unnecessary paper trails?
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 ..."
US Person and NRA on account? Whose TIN?
10/13/2019
If there is a US Person and a Nonresident alien on the account, do we have to have a FTIN?
