Are there best practices for tracking loan policy exceptions?
My question has to do with scams involving fraudulent checks and how we should handle the check when a customer presents it for payment. Specifically, we had a customer bring in a check for $2,900 that just didn't feel right for the type of business the customer normally conducts. The teller inquired about the check. The customer explained that he had enrolled online as a secret shopper. He was to keep $300 for himself and spend the other $2,600 buying specific merchandise to send back to the company that sent him the check. The teller called the bank on which the check was drawn and was told that it was fraudulent. We have had a law enforcement official tell us that we need to deposit the check anyway, put a hold on the account so that the funds are secured, and wait for the check to be returned so that we have a paper trail and proof that the check is fraudulent. In addition,
once we have proof that the check is fraudulent, we should give the returned check back to the customer so that they can file a complaint with law enforcement. Is this the proper way to handle the check?
Where in the FFIEC IT Manual does it state that it is recommended to have a wire transfer policy?
Our bank is basically taking the position that we will not provide services to marijuana related businesses. We need to add this verbiage to our policy but I am unsure of the best approach. My thoughts are..
*We will not provide banking services to marijuana related businesses. (straight forward)
*We will not provide banking services to entities or individuals who activity is not considered legal at the state and federal level. (not segregating a specific business)
*After conducting a risk assessment we have determined that we will not provide banking services to marijuana related businesses.
Any insight you may have is appreciated.
With the escrow ruling becoming effective January 1, 2016, does anybody have any sample correspondence that they are sending to their borrowers explaining this new rule and the requirement to escrow their flood insurance premium?
Our BHC previously held an FDIC, state-chartered bank and a trust company as separate entities. The trust company is now in the process of becoming a wholly-owned subsidiary of the bank. The long-time personnel of the trust company will continue to operate the trust company as it always has. Since the regulatory oversight for the trust company will now shift from the FRB to the FDIC, is it acceptable for the trust company to maintain its existing policies and procedures separate from those of the bank?
How long can you place a Hold on a Large Check Deposit made to a Savings account?
Do you have a sample of a Reg.O policy?
Are appraisal reviews required on all new real estate loans that require an appraisal?
We have a case-by-case hold policy at the bank where I work. We give a written hold notice to customers when we are placing a hold on their deposits. We have one customer who makes multiple deposits each week. Due to the history on the account, we place a hold on all check deposits into this account. The customer is aware of this. Are we permitted to forgo the written notice step of the case-by-case hold for this customer?