What is demonstrable consent and can we do that with new account disclosures we email the new customer?
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?
The NCUA has a regulation that will not allow a federal Credit Union to close out a member's relationship without being approved by the NCUA Board. However, the FFIEC manual allows for an institution to close out a member due to multiple SARs. Does the FFIEC Regulation supersede the NCUA regulation that requires approval before closing out a relationship?
Is it a requirement that all archived loan statements have the "backer" information on it meaning the Reg E language, bank logo, copy of paid checks, etc...?
Do you have a form letter template or suggested text that can be used when we receive a legal issue from outside a jurisdiction we would otherwise have to honor, stating we will not be responding and that legal issues must come from our areas we are subject to?