Most Popular Compliance Content
Temporary Servicing Disclosures for Loans and Depo
04/16/2023
We have a very small subsidiary bank whose contract with its core systemes provider is not being renewed. The bank obviously needs a temporary core system until they close a new contract with another provider. One proposed solution is to onboard the small bank's 100 or so customers onto our core. We would manually process the small bank's transaction files from imported data, which our IT teams are handling. Bottom line, the small bank will retain its ABA#, but their debit cards will have to be reissued by us, the larger bank, and during the transition the cards will bear our name. My concern lies in disclosures and compliance. What disclosures do we as the larger, "host" bank need to provide to the smaller bank's customers while their accounts are serviced by us, on our system? The smaller bank is a digital-only bank.
Business Account Registration Requirements
04/09/2023
When opening a business account, is it required that a bank have the company register with the state that the bank is located in? For instance, we see quite a few companies that are registered in Delaware but the company also operates in Tennessee. I know they should register with the Secretary of State in TN, but is it the banks responsibility to manage that process and make them do it before we open an account for them? Will any of this change with the new beneficial ownership rules?
Rep Payee Account Restrictions
04/09/2023
I was recently told that Rep Payees for veterans specifically, were restricted from having transfer capability via an online banking profile. Is that correct, and if so, when did that go into effect and where is that rule?
UDAAP penalties are costly
04/09/2023
How much "teeth" does UDAAP really have to penalize a bank?
Are We Required to Monitor Our Moderate Risk Customers?
04/09/2023
Our automated surveillance monitoring system identified 400 customers as moderate risk. Are we required to monitor the activity?