Is it a requirement to add/update our USA PATRIOT Act notice at CSR desks and disclosures for the CDD/Beneficial Ownership requirements, at account opening?
I attended Ken Golliher's seminar yesterday in Tulsa, it was very informative. I understood him to say that even if we don't do international transactions at this time, that he would still advise us to address Section 311 (Special Measures) of the USA PATRIOT Act in our policy/procedures. I was hoping someone
could weigh in on this for me.
What is the difference between Section 311 and Section 312 of the USA PATRIOT Act?
Attention Deficit Disorder
by Mary Beth Guard
Recently, I was diagnosed with CRADD:
I'm new to BankersOnline.com and also to compliance. I am trying to find some training materials relating to the USA Patriot Act that I could potentially use as a model for staff training at our bank. Can you point me in the right direction?
Is an adverse action notice required where an application meets all credit risk criteria and is credit approved, but is officially "conditionally approved", wherein the only condition not met is that the lender is unable to clear verification flags to meet USA PATRIOT Act requirements before opening the account?
According to the USA PATRIOT Act Section 326, a customer includes the person who opens an account for an entity that is not a legal person. How do you determine if the entity is legal? For example, we have a bowling league. Do they have to register with the state they do business in to become legal? Do they have to obtain a TIN to become legal, or both?
Question: What should we do to comply with Red Flags risk assessment requirements?
An issue has arisen at my bank concerning the need for a signatory on a homeowners association account to submit his social security number. My bank's BSA Officer believes that he must do so. I am not so sure. This individual has no personal accounts with our bank, but is listed as a signatory on two accounts dealing with homeowner's associations. The person in question refuses to give his social security number. How are HOAs classified for purposes of the USA Patriot Act? It's my understanding that the HOA is the owner of the account. I know that the signatory situation was in the proposed rules, but not the final ones. I would appreciate it if someone could provide me with some guidance.