I understand that Reg Z requires us to set up an escrow account for loans that qualify for HPML. If the security is made up of separate tracts of land and only one of the tracts includes the first lien on a principal dwelling are we required to escrow for taxes and insurance on the other tracts of land?
I read the comments and the instructions regarding the expiration of W8BEN. Once the W8BEN expires, does the Bank just require another completed W8BEN or do we need to take other action?
I participated in a recent seminar where BOL Guru Dana Turner was the presenter. He mentioned that there might be a conflict of interest if the bank's Security Officer was also a director. I am in that position and I have discussed this with the Board/Executive Committee and was told today that they had talked with our bonding company and were told this was not an issue. What is the rational for ensuring that our Security Officer should be an employee, rather than a director?
I am setting up an account for a "Living Trust". Can I style it: "ABC Living Trust"(using grantor's SS# John Doe trustee or do I have to use grantor's name ss# then ABC Living Trust then John Doe Trustee?
Does the bank require Letters Testamentary dated within 60 days to cash in a CD belonging to the deceased? Is there a central database containing CD information? Can we search accounts by his social security #?
What is the most current decision on a bank off setting an overdrawn account that gets Social Security deposits?
The husband of a long time customer of the bank, is using her account to deposit large dollars in postal money orders, cash, his social security check and wires for services he provides. The money is then Paypal'd out. We have no idea of the source of these funds. Her paycheck is an ACH not in questions. We have been filing SAR's for a year. Should we leave the account open?
What are the proper procedures to CIP for an attorney-in-fact (AIF) under a power of attorney? My question comes from an instance where we have a CIP grandfathered Amish customer and they would like to add someone to their account that doesn't have a TIN and refuses to get one. They went to an attorney to get around the CIP restriction and made him an AIF so he wouldn't have to go through the normal CIP process. Is an AIF considered a customer under 103.121?
We have customers who have social security checks for dependents made in the following manner: "John Doe For Jane Doe" wherein in some cases the dependent is either a child or disabled person. I argue that these checks are payable to "John" as he is the first payee, and "Jane" is not actually a payee. Therefore, the check should be negotiable by John, or depositable into an account held solely by John. My FI has recently instituted a rule requiring these types of checks to be deposited into a) a UTMA account for "Jane" b) a Rep-Payee account for Jane or c) an account held solely by Jane. As in many cases Jane is either a minor or disabled, I believe forcing an account to be opened under her name to be irresponsible banking. I would like to know the guidelines for negotiating a check made either to "John Doe For Jane Doe" or "John Doe For the Benefit of Jane Doe"
Do we need to run OFAC on a newborn baby whose mother or father have opened a savings account for the baby? We do have the Social Security number for the newborn.