Most Popular Compliance Content
PayPal was used – is this our Reg E claim?
11/28/2021
What if the customer says that they don’t have a PayPal account? And they don’t know how PayPal got their information, can you deny the claim and have them contact PayPal?
Package Delivered to Wrong Address – Reg E?
11/28/2021
When we receive a pre-arb for a fraud transaction that shows proof of delivery to the address on file, the tracking info just shows city and ZIP for it being delivered. But when the member went to the post office to get more info, it shows it was delivered to a different address in their neighborhood. Any advice on how we should proceed with these pre-arb responses if we do not have the ability to get the post office info to get the exact address?
Cashing Check on DBA/Sole Prop for Business
11/21/2021
Can a customer cash a check on a DBA/Sole Prop account if the check is made out to the business?
CTR Dilemma- Proof of Funds for Transfer
11/14/2021
We have a CTR dilemma. A customer came in with $20,000 cash. - The funds were first deposited into his account. - He then wanted to purchase a cashier check for $7,000. - He returned later the same day with an account number of a family member and wanted to transfer $18,000 using the cash deposit and preexisting funds from his account. He is not on the family member's account. The reason stated was that they are in the process of buying a house and escrow wanted him to show the proof of funds in a statement which was the reason for the transfer. How would you complete the CTR in this situation: is there only one Part 1 (customer) or two Part 1 (customer and family member)? And the $7,000, would be under negotiable instrument and $13,000 under fund transfer? We also plan on filing a SAR.
Unemployment /Economic Impact Payment Fraud
11/14/2021
FIN-2021-A002 and FIN-2020-A007 describe Unemployment and Economic Impact Payment Fraud that financial institutions should be aware of. However, the economic payment amounts and most unemployment insurance amounts are below SAR reporting thresholds. Is there a requirement to look for and file a SAR for these types of fraud even if the amount is below the SAR reporting threshold?