A deposit was made into an IOLTA Account, but the lawyer did not tell us who this was benefiting, how do we file the CTR?
We have an affiliate under our Bancorp that does 1031 Exchange Services. I want to do a risk assessment on this service but I am not sure what the risks are?
We deposited an item for a member on 06/14/12. The item has been returned to us today (07/10/12) as "refer to maker" "altered item." I believe we can refuse the return due to the 24 hour return deadline being missed, is this correct?
I've been asked to research what compliance issues there might be with changing our CD early withdrawal penalties from interest based (e.g., 3 months interest) to principal based (e.g., penaltiy is 1% of principal amount at opening or renewal).In what I've been able to find, the only thing I see relates to the Reg D requirements for the penalty to be at least 7 days simple interest if the withdrawal occurs within the first six days to be considered a time deposit. Assuming we can cross that hurdle, are there other compliance issues that I'm missing? UDAAP potential comes to mind, but if we are clear and transparent in disclosing the penalty are there other aspects of UDAAP that could bite us? We are looking at this as a defensive/customer retention tactic. With today's rates so low, and as a result with interest-based early w/d penalties also low, customers have no real downside to locking in higher yields today by putting into long term CDs with the thought that if rates jump significantly in a year, the penalty will be more than offset by moving to a higher yield CD early.I'd be interested in hearing any thoughts. We have heard anecdotally that other banks may be considering or already doing this. Is anyone aware of a bank doing this at this time?
I recently took over in the compliance area at a financial institution. I have been doing research on disclosure requirements. I have been reading UCC statutes and they only state that certain signs be posted in the lobby of the bank. However, I cannot seem to find whether they have to be a certain font size, bold, etc. Is there any language that states the required lobby postings must be a certain font or not?
There was a previously posed question under "Regs Triggered Due to Increased Asset Size", relative to a bank's asset size growing to $500 million or more. The answer implied that there my be state laws that apply, but did not indicate where that information could be found. My bank is not a publicly held bank. It has grown to slightly over the $500 million mark. Bank maangement is actually wanting to shrink below that amount by year end 2010. Do any of the SOX provisions apply to us? The SOX act specifically states "It does not apply to privately held companies." How true is that statement? What Kentucky state laws may apply regardless of that SOX provision? I have researched many facets of SOX information found on BOL and, quite frankly, I'm more confused now that when I began my research.
We have opening procedures for each branch. On occasion, an executive will come in early and completely ignore the procedures we have in place. This leads other employees to disregard them as well. What can I do to make this easier on everyone?
When was Reg D first enacted? I can find every piece of info about the regulation except this one.
With regard to website changes (disclosures, marketing advertisements, general changes, etc.) is there a concrete retention schedule or best practices for retention? I see many companies treat these changes like a hard copy advertisement change. They will print out the archived page and save it for the examiner. If this is the case, is there a time frame to keep these archived print outs or do you just save them between examinations? I couldn't find any information on the FFIEC website that explains a policy and any website research is very vague.
What changes were made to Regulation DD in 2008? My co-worker said there was an additional one besides the overdraft disclosures that are being required as of 01-01-2010. Is my co-worker correct?