Our company supplies software for banks and credit unions. Many of our clients offer HSA accounts. We have been asked more than once about how to account for a reimbursement of a distribution that ended up being for a non-qualified expense. So say someone uses their debit card to purchase something they thought was qualified but later finds out it is not. Instead of taking the penalty on that withdrawal, they would like to reimburse the account for that expense and in essence, make it disappear. Is that possible to do from a compliance standpoint?
How long can you place a Hold on a Large Check Deposit made to a Savings account?
Is annual board training of BSA a requirement or just strongly encouraged? At all report times and policy approval BSA is discussed in depth. Does anyone have some updated BSA board training material?
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.
In a training last week it was brought to my attention on the new CTR form that it is requiring the ID collection of an entity. In the past this has never been the case and in the FFIEC manual it specifically refers to individuals. FinCEN has said that there is nothing new to the forms except the collection of the new fields. Not in any webinar or documents that we received from FinCEN said anything about identifying document collection of an entity for a CTR. The only thing I have seen regarding this is actually on the form from the help box in the ID field itself. Is this something we have to collect going forward?
On IRAs, upon death of the owner, may the beneficiary (spouse) roll that amount into their own IRA? And, can the beneficiary spouse receive the entire IRA as a distribution.
June 15, 2011 titled Debit Cards - Error Resolution Problems Solved. In that training, there were slides on cancelled recurring transactions that stated that these types of transactions were not covered by Reg E. Could you please provide the reference in Reg E where it supports that a transaction that occurs after the recurring transaction is cancelled is not considered unauthorized and therefore not covered by the regulation.
Does the bank courier need to receive annual training on BSA? He is employed by the bank but does not process transactions or have a desk/office in the bank?
The December 19, 2011 BankersOnline Weekly Banker Briefing contained an article under the lending section titled, "Requesting Tax Returns at Time of Application." I believe the answer given was incorrect. The BOL Guru stated that you can not "ask for verification documents until after the GFE is delivered and the applicant has indicated they wish to continue." What the regulation actually states is that you cannot require, â€œas a condition for providing a GFE, that an applicant submit supplemental documentation to verify the information provided on the application.â€ Is this correct?
Under Reg GG, how does Internal Audit go about setting up a review that will satisfy the regulators?