Can we refuse to send an international wire out if we suspect fraudulent activity?
Is there a Record Retention Period for a MasterCard Account Number on file? We are the issuer of the card and the Bank continues to hold the account number on file even when it has expired. Do the same rules, if any, apply for VISA?
Are financial institutions allowed to implement an ACH debit policy that limits the number of ACH debits once the account has gone negative, in an effort to prevent substantial ACH NSF fees and potential losses?
Are there any rules that would prevent us from reissuing a cashier's check every few months for a customer? She comes in and wants a fresh check but never cashes it out. Is that a reportable suspicious activity? Are we breaking rules by doing this?
We are looking at revising signature cards for an existing HOA management company and their subsidiaries. We are adding an employee and deleting an employee. If the employee is just an authorized signer and not an owner or person in control, do we need to gather or require the beneficial ownership certification? This relationship was created before the regulation went into effect. We have nothing on file regarding beneficial ownership and are wondering if this would be a “triggering event”?