I want to be sure we are correctly handling the annual report that needs to be made on compliance with the Red Flags rule. Two questions: Does the report have to be made to the Board of Directors and what is the content of the report.
marIt’s been about five years since we updated our Red Flags program. Do you think we’re still okay?
Are there any rules against an individual / consumer having a repurchase agreement?
Is it permissible for the government to simply give us the certificate of compliance at the same time they give us the subpoena?
We use a solution provider for our mobile application. Does the new mobile financial services guidance require our vendor to enhance security to meet expectations?
We have a dummy camera over our outside employee entrance door. Doesn’t that provide safety?
Is a beneficiary on an account also the beneficiary on a CTR? For example: checking account is a sole-ownder account in the name of Mary Smith, her son John is listed on the account as beneficiary. Mary makes a $15,000 cash deposit. On the CTR is John also to be listed as beneficiary? I know that all joint owners are, but can't find anything that pertains to this, because if Mary were to pass away the funds become John's (So he could ultimately benefit from the funds).
If a branch made us aware of Suspicious Activity, and we determine a SAR needs to be filed, would we mention the fact that we were made aware from a branch or just say we were made aware in general, should we ever get the branch involved.
A US Treasury check made payable to a father for his son (Roy Boy for Ray Boy) was cashed over $10,000. Do I list the son as benefiting from the funds or do I only list the father as the conductor and who benefited?
Regarding HMDA, we have two different answers as to what defines a Bridge loan. They are basically the same answers with one exception: if the loan is secured by BOTH dwellings (existing one and one to be purchased); OR if the loan is secured by ONE dwelling (either existing or one to be purchased). As I said, I understand consistency is the key to remaining violation free in this area, but again, I would like to know how the majority views this detail of a Bridge loan.