What compliance risk is there associated with one of our business deposit account customers asking us to cash checks for their employees? The employees do NOT bank with us AND the payroll account is drawn on an outside bank. I am worried about the CDD and the BSA aspects of engaging in this type of activity. Any thoughts?
How do I start preparing for the new Beneficial Ownership/CDD rules?
Vendor “v” Compliance and I’m in the middle. Scenario; Our customer goes to a casino, casino issues a card, customer uses it at the casino, casino uses POS entry class code and runs it through ACH network, customer does not have a debit card with us or has not OPT-IN. If the transaction is NSF can we assess a fee? I know we can return if necessary, our vendor has an identifier on the transaction so we know it came through ACH and can return it but have been told we cannot assess a fee unless the customer has OPTIN. My interpretation of 2017 NACHA rule book pages ORxxxvi, OR 18 and OR60 is that banks should be able to assess a fee because this is an ACH transaction not a Debit Card (POS, ATM) transaction. Which rules apply to this transaction?
Regarding safe deposit box entry, what is the Bank required to document each time a customer enters their box? Do we have to log a primary I.D. or can we rely on Know Your customer standards?
We have a single-member LLC using an EIN number. The member is asking what happens to the account when he passes away, will it go to his estate or does it need to be in his business papers to show where is goes? The account is held in Iowa and they run the business out of Minnesota.