Is there anything in Reg O that prevents senior management (V.P. or higher) from receiving the same employee benefits as lower level employees such as fees waived on the purchase of official checks and money orders?
I know you can't "stop payment" on a cashier's check but you can "refuse to pay" if the remitter or payee asserts a claim in writing because the check is lost, destroyed or stolen? Can we charge the customer our Stop Payment Fee of $20.00 for this service or would we have to change our Schedule of Fees to include a "Refusal to Pay" fee before we could charge for this service?
Our Official Bank Check vendor says that we shouldn't worry about how they handle escheatment (one lump sum with "payees unknown") because they are following the rules regulating their industry. Our question is, if we as a bank have hired this vendor to do a job for us, what is our liability with our examiners? Do we take this vendor at its word?
Is an Official Check considered the same as a Cashier's Check under the Reg CC next day availability rules?
We are having a discussion regarding OFAC and the checking names of payees for cashiers checks. One person believes all names must be checked, purchaser status customer and noncustomer. The second opinion is: names of payees for cashiers checks purchased by noncustomer only are to be checked. Who is correct?
We have been informed that it is now a requirement to maintain 30 day records of purchasers of Official Checks/Cashier Checks with the requirement to report multiple suspicious purchasers within the 30dy period. Is this a specific BSA or USA Patriot Act requirement?
Our bank has had a couple of incidents where a customer will buy a bank money order, (our form of the cashier's check), with cash and in an amount that causes us to have to file a sales of monetary instrument report. Then days later they might bring the BMO back in and purchase another BMO with it for a smaller amount and receive cash back. My questions are: are we obligated to file a second monetary instrument report, and can a money order be purchased with another money order?
Question: We've been keeping a log on all our customers, exempt or not, for cash transactions over $3,000.