Most Popular Compliance Content
Handling Multiple Regulatory Disclosures
04/18/2005
I am with the trust compliance risk management department and perform compliance reviews for advertising and presentations that frequently involve products from multiple business lines: e.g., a wealth management piece may include reference to private banking, estate and wealth planning, insurance, investment management and brokerage services. How do you handle the multiple regulatory disclosures (FDIC, Equal Housing, Interagency statement, etc.) without completely cluttering the material with disclosure?
Copy of SSN Card
04/18/2005
Is it an IRS regulation that a bank cannot take a copy of a social security card? Can we have a copy in the customer's new account file?
Template Letter for Excessive MMDA Transactions
04/18/2005
In a recent compliance exam, we were criticized for the wording used in a letter to notify customers of excessive withdrawals from their money market accounts. The wording was "too harsh" and we were told it should be softened to "we may" instead of "we will," etc. Do you have a model letter form? I have not been able to find one. Thank you.
When to File a 1099-C
04/18/2005
I have some questions regarding the IRS reporting on 1099-C cancellation of debts. 1. Are personal bankruptcy accounts reported if they have been discharged? 2. Are you required to report charged off loan accounts before the statute of limitations (15 years) for collection has expired? 3. If you cancel a debt can you no longer pursue collection of that debt?
Enhanced Due Diligence on a 34 Act Company MSB?
04/18/2005
Per the BSA, an MSB does not include a bank, nor shall it include a person registered with, and regulated by the SEC or the Commodity Futures Trading Commission. Does this mean that I do not have to perform any enhanced due diligence on an MSB that is a 34 Act company? By enhanced due diligence, I mean determining whether the business has procedures to comply with applicable BSA requirements, whether the company has proper controls to monitor for suspicious activity and whether the company has procedures to ensure compliance with OFAC regulations