I am seeking some advise on BSA regulations around aggregation of secondary account holder. Is it a requirement by FinCEN to aggregate transactions based on secondary relationship between accounts and file a CTR? Example: Joint account relationship Account (A) - Chris (P) / Joe (S) Account (B) - Joe (P) / Brian(S) Chris as a conductor makes 6K Deposit into Act A at Branch X Later, Joe as a conductor makes 5K Deposit into Act B at Branch Y should a CTR be filed considering Joe has secondary relationship with Chris in Account A and ultimately benefits from the deposit made?
Are we required to provide a copy of the NACHA rules to our customers that originate ACH transactions?
We have a business customer that mailed a check to a business for payment, and that payee is claiming they never got the payment. We can see the check cleared our customer's account in February 2018. We feel it could have been intercepted by a third party and negotiated. The BOFD did confirm that the check was negotiated at their institution, but obviously can not confirm who the third party is, or if it is in fact a third party. Do we have any recourse on this? We were thinking a warranty claim but do not have much experience with this or where to find those forms.
Under the proposal can we use social media to contact a debtor?
Will there be future Reg CC inflation adjustments? How often?