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.
We have customers from Mexico that have been lawfully admitted to the US on a temporary basis who have DHS authorization to work. The Social Security Administration has issued them a SS card that states;Valid for work only with DHS authorization. Do they sign a w-9 or W-8 for their loan?
Can an LLC using a social security number have more than one signer?
When training bank employees, what is the minimum training allowed? We are getting a new core this year and it is going to monopolize a lot of time training for it. We want to stay within the legal guidelines and maintain a curriculum, but need to streamline it for core training purposes.
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?