Most Popular Compliance Content
LAR Formatting Tool
11/14/2021
What is the LAR Formatting Tool?
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?
Reg E Discl. Given to Business Acct.
11/14/2021
Can you go over the Reg E disclosure given to businesses? What is their liability?
Debit Card Returned, Card Info Used
11/07/2021
If after the suspect gave “Tiffany” her card back, he used her card number to make an online purchase without her knowledge, is she still liable even though he gave her the card back?