Latest Compliance - Risk Assessment/Risk Management Topics

BSA Risk for Coin Operated Amusement Machines

09/08/2019

Can you refer me to the guidance for assessing the BSA risk for coin operated amusement machines operated in convenience stores who happen to be a customer of our community bank?

When do we have to report contest winnings to the IRS?

08/04/2019

We ran a contest and no prize was over $300. We didn’t need to collect non-public private information from the winners since the prizes were small, did we?

Notifying consumers of improved funds availability

08/04/2019

Will we have to notify our customers or members of the inflation-related changes?

Wait time between debtor conversations.

07/28/2019

If I get a promise to pay two days from now on Wednesday and they don’t show, can I call Thursday morning?

With lottery exceptions, can we advertise for others?

07/28/2019

Now that banks can participate in lotteries, can we facilitate raffles unrelated to the bank for local service groups- post lobby posters or sell tickets for or be a sponsor, etc.?

Changes to Reg DD in the June 2019 Reg CC final rule

07/28/2019

What are the changes the rule will make to Regulation DD?

Marketing to staff, same rules as to the public

07/21/2019

Can we do an internal raffle (selling tickets for a chance to win a prize) to benefit a non-profit organization?

Impact of EGRRCPA amendments on Pacific Islands banks.

07/21/2019

Will my bank be affected by the change involving U.S. Pacific Island banks?

Reg CC’s $100 rule FINALLY gets updated!

07/14/2019

Will the $100 next-day availability rule be updated?

Can we offer a prize to everyone, for charity?

07/14/2019

We have a “spin the wheel” promotion. To spin, a customer must donate $1 that the bank donates to a charity. All the prize amounts on the wheel are more than $1 therefore all customers will get more than they donate. The amount won is then sent to the customer via our e-wallet app. We set a certain number of spins and it is done on a first-come-first-served basis.