Our attorney posed a question to me that he received from a customer. He wants to know under what circumstance do we change our deposit disclosures? I told him when we have a regulatory change or a policy/product/service charge or other change. Also, I said if the change is adverse to the deposit customer we have to notify them in a certain number of days according the change requirement or regulatory requirement. If the change is to the customer's benefit, we may or may not do a mailing and just post it on the website, social media or on the their statement. Our attorney wants to know the general rules for account agreement changes, when to change them and where it appears regarding the adverse change or customer benefit change. Any thoughts?
Should the owner of a sole proprietor business account cash checks made payable to him personally using the business account?
If a customer purchases a cashiers check with cash over $10,000 I know the CTR is required, but are we still required to do the check log? I thought the check log register was only for amounts $3,000.00 - $10,000.00.
What are the requirements in relation to counseling reports for excessive overdrawn accounts and what regulation can I find that in? We already send notification out each time an account is overdrawn more than 6 times in a 12 month period. We also contact customers via phone and letters at 15, 30, and 45 days of being overdrawn. Are we required to mention "counseling?"
We need to do a CTR for an ITF account because the custodian came in and withdrew over $10K. For filing guidance we see examples of deposits, but not of withdrawals. Should the beneficiary of the trust be on the CTR assuming that funds withdrawn were for them? All we know is that the beneficiary walked out with the money. Also, should "ITF" be shown on the CTR anywhere?