Most Popular Compliance Content
How to Complete a CTR for an Estate
10/13/2019
How would I complete a CTR for an estate? The Trust Dept. opened deceased customer's safe deposit box and found $75,000 in cash. Funds were then deposited into a trust fund. I know the trust employee will be the transactor but how do we handle the "on behalf of"? Do we just put customer's name even though he is deceased? There's no where to put "The Estate of ..."
Debit Card Fraud Claim for Activated Card
10/06/2019
We have a member who is filing debit card fraud and claims that his card was not received in the mail. The card was activated and the caller used the correct last four of his social security number to activate it. Is this enough to deny the disputes?
Sole Prop Using Personal Joint for Business
10/06/2019
What are your thoughts on a sole proprietor using a personal joint account for business transactions? Merchant deposits and payments are going in and out of the account (less than 15 transactions a month). We have insisted that our customer open a business account for his sole proprietorship. Is it wrong for us to require it?
Advertisement for Bonus Reg DD
10/06/2019
This is about an advertisement that offers a bonus to a customer and one of the conditions to be met in order to qualify for the bonus is having a set number of debit transactions posted to the customer's account within a specific period of time. When disclosing this qualification in the ad for the customer, should it be specified as "posted and cleared to your account" to be more clear and conspicuous or is the language "posted to your account" sufficient? Does Reg DD indicate the need to specify the term "cleared or completed" when referring to posted?
Deceased Business Customer-Documents
10/06/2019
A business customer died 2 1/2 yrs ago. Due to estate disputes, an attorney was assigned to settle the estate. Recently the attorney sold the business. The attorney and the new owner came to the bank and requested to have the attorney's name removed and to add the new owner to the existing account. Due to several family members of the deceased having all the account information, I informed them that I would need to close the existing account and open a new account. The attorney was not happy. They did not bring documents reflecting the sale of the business or documents reflecting the owner name change being filed. What is the standard or best process for this type of situation? Should a new account be established if the required documents are presented or is it acceptable to simply change names and keep the existing account open?
