What happens if you forget to send the CTR by the 15th day?
I have been reading about revisions to BSA, primarily chapter X. Could you please fill me in as to how this affects our bank and what measures we may need to take for compliance purposes?
Earlier I thought I read that the changes to Reg CC included reducing exception hold days. I haven't heard anything else about this. As we change our policies to reflect the $200 availability, should we be addressing the days we can hold a check as well?
I'm new to BankersOnline.com and also to compliance. I am trying to find some training materials relating to the USA Patriot Act that I could potentially use as a model for staff training at our bank. Can you point me in the right direction?
I have discoverd that my CSRs are placing holds on checks for one of our customers, sending or giving the notice. They are then waiting a day or so and calling the bank. If the check that they placed the hold on has cleared, they release the hold early. What are your thoughts? I believe they are at the very least circumventng our policies.
The FDIC's Overdraft Supervisory Guidance says that institutions are expected to have procedures and policies in place by July 1, 2011. I am trying to understand if a fee is charged on the sixth occurrence, but waived three weeks later. Does an institution need to adjust the occurrence count back to five? Does waiving of the fee need to occur at the time it is charged for the overdraft?
What encompasses a Remediation Life Cycle (RLC)?
Do we have to have job specific training for BSA?
Could you direct me where to find in the Dodd-Frank Reform Act where the change to EFA from $100.00 to $200.00 will be happening. I know I read it and now cannot find where I read it. I checked EFA Reg but it has not been updated, but we have updated our disclosures and signage to reflect the $200.00.
Is a W-8Ben required when opening a non-interest bearing account for an Non-Resident Alien?