Most Popular Compliance Content
Risk Analysis: Opening Deposit Accounts
02/01/2005
In this grid, we lay out risks associated with the branch activity of opening accounts. Whether customers are new or repeat, each of these compliance issues can be triggered.
Deposit applied to wrong account - Now what?
01/31/2005
A family friend made a deposit of multiple checks. He did not have a pre-encoded deposit slip, but did fill out the deposit slip completely otherwise. The teller receipted the transaction correctly, but encoded a completely different account number on the transaction. That account number belonged to the depositor's mother. (Even though the two are not on accounts together.) The error resulted in two checks being returned, which caused additional late fees and charges to the depositor. Since the transaction was correctly receipted the depositor was unaware of the problem until he received NSF notices. What is the liability of the bank to correct this problem? And what is the recourse of the depositor?
RFPA and Subpoenas
01/31/2005
Concerning the Right to Financial Privacy Act and subpoenas: When we receive a subpoena, has the government authority who issued it already notified the customer at least 10 days in advance, or does the government mail/deliver the subpoena to the bank and customer at the same time? This would mean the bank must wait at least 10 days to provide the information in order for the customer to have time to stop the request.
Family Trust as Beneficiary?
01/31/2005
Is it acceptable to style a deposit account with a family trust as the beneficiary? A customer has requested an additional account with him as the sole owner and his trust as the beneficiary in order to get additional FDIC coverage and keep his assets ultimately in the trust if he dies.
BSA Training Is For Everyone!
01/31/2005
I'm the Internal Auditor of a community bank and will really appreciate your help with this. I'm working on the BSA Internal Audit and was trying to see if the FDIC/State requires for all employees to complete their BSA training, regardless of their department? We have a very good compliance program and training but it seems that some of the Loan department has not finish or even started with their online BSA training. Should I include as a recommendation to make sure that all employees complete their BSA training or should I write it up as violation? If you advise me to write it as a violation, give me good arguments because I have a stubborn Compliance Officer. Once again I would like to thank you for your time and assistance.