As a former government employee, I have seen this happen before.
Our bank was presented with a court order requesting numerous documents on a customer for a divorce action. Can we charge a research and/or copy fee for the work done to comply with this order?
FinCEN has announced a significant delay to the customer identification rules. It has also announced that compliance will not be required until long after the final rules are issued.
FDIC is under new management. The Honorable John Reich, Director, FDIC, addressed the attendees at ABA's National Regulatory Conference and outlined the agency's new priorities.
The Consumer Advisory Council ("CAC") met for the second time this year and discussed the hottest topics of interest to consumers: privacy notices and CRA.
No matter how you count or measure compliance risk, Truth in Lending has led the list for decades. The number of errors that translate into violations is always high.
In Ken Golliher's presentation materials for the SAR telephone seminar there was a step/action table on page 22. For step 4, a committee reviews the info and determines whether the situation requires a SAR filing. If no, a notation is made on the summary and it is retained for 18 months, then destroyed. Is the 18 months a regulatory requirement or a best practice?
A former bank customer recently opened a business account with us. When this nonlisted business originally banked with us several years ago, it was designated as an exempt person with respect to the currency transaction reporting requirements. They've asked to receive the same designation as before. However, the regs state that a nonlisted business must maintain a transaction account at the bank for at least 12 consecutive months before filing for an exemption. In light of the fact that this business formerly had an account with the bank,and was designated as exempt, can the 12 month requirement be waived in this case? The customer is very vocal about this and has been pressuring our frontline personnel for an answer.
Jim Harper, president of Privacilla, in his speech to the privacy conference hosted by the Progress and Freedom Foundation and the Pacific Research Institute, raised the core question: what is priv
On 9/3/01, a question regarding <a href="http://www.bankersonline.com/compliance/gurus_cmp0903c.html">"FTC Notice/Notice of Holder in Due Course"</a> was answered by Jim Bedsole. In our case, his answer states if we have a floor plan agreement with Dealer A and a borrower purchases an auto, but directly finances with us, the notice would still be required. He also stated this could be found at 16 CFR 433 and in the FTC Staff Commentary. My questions: 1) Where is the staff commentary, so I may provide to my attorney? and 2) what types of "claims and defenses" could a debtor assert against the seller?