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?
We are starting up a new debit card program. I need help on what policies I need to make sure that I include in our debit card program. Prior we only offered ATM cards. What disclosures do I need to be mailing out? I figured I needed to mail out new EFT disclosure and Reg E disclosure. What kind of offline limits do I need to set for our customers? Is there a Regulation on that?
I know OFAC is not the government list required to be checked under BSA. What was the date that Bank's were required to check the OFAC list on new accounts?
What are the proper procedures to CIP for an attorney-in-fact (AIF) under a power of attorney? My question comes from an instance where we have a CIP grandfathered Amish customer and they would like to add someone to their account that doesn't have a TIN and refuses to get one. They went to an attorney to get around the CIP restriction and made him an AIF so he wouldn't have to go through the normal CIP process. Is an AIF considered a customer under 103.121?
Do we need to run OFAC on a newborn baby whose mother or father have opened a savings account for the baby? We do have the Social Security number for the newborn.
Under Reg GG, how does Internal Audit go about setting up a review that will satisfy the regulators?
Since Reg Q was removed/revised this year, do we need to do anything formal with the board to delete our policy for Reg Q? Or do we not get it reapproved this year? Our compliance officer was not sure.
If a borrower is refinancing, paying his own escrows, and the insurance is in effect for an additional year, does the premium need to be disclosed on the good faith estimate?
What method(s) are being used to determine insurable value when calculating the appropriate amount of forced placed insurance?
Can you provide a list of required officer positions? Are these requirements listed in the regulations or are they simply suggestions? I'm trying to determine which officer positions are mandatory for compliance so I may pass this information on to Executive Management.