Most Popular Compliance Content
IRS Levy Payment After 21 Days Code Details
09/29/2019
An IRS levy requires payment after 21 days. - When the 21st day is on a non-business date, when should the funds be sent? - Are the 21 days calendar days? I have found no information in the IRS codes addressing the details of 21 days.
Beneficial Ownership Information Clarification
09/29/2019
XYZ, LLC was opened with a certification of two individual signers owning 10% and 16% of the company. However XYZ’s company agreement stated that another LLC (ABC, LLC) owned 90% and one individual (one of the signers) owned 10% interest of the company. The ABC, LLC was not indicated on the certification. Based on the XYZ’s company agreement, do we need to request beneficiary ownership information on the ABC owners?
Send E-SIGN with Disclosures
09/29/2019
What is demonstrable consent and can we do that with new account disclosures we email the new customer?
Check Correspondent Banks on OFAC? Wire Transfers
09/29/2019
We are a de novo bank and our BSA officer mentioned that it was "recommended" by FDIC regulators that banks need to check their correspondent banks on OFAC anytime they send or receive a wire from them. To me this seems pointless and quite excessive. We send/receive wires through PCBB and I can't see us needing to check OFAC lists for their name daily. Is this really necessary?
Reg CC RDC Indemnity:Liability and Timing
09/29/2019
For the Reg CC RDC indemnity, it states; "(2) A bank described in paragraph (f)(1) of this section shall indemnify, as set forth in § 229.34(i), a depositary bank that accepts the original check for deposit for losses incurred by that depositary bank if the loss is due to the check having already been paid." We have a customer which is a business offering check cashing and it makes deposits via remote deposit capture. I am confused over the liability and timing of paper vs. electronic deposits, duplicate items and will restrictive endorsements influence liability?
