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Latest Compliance Topics

Implementing eSign: Signature Cards/Resolution

01/03/2021

We are on the verge of implementing eSign for our branches for maintenance tasks in addition to account opening and lending. I think this will help with some customers who tend to change signers rather frequently, such as with closers on settlement agents' accounts. I'm beginning to consider whether collecting their signatures on Resolutions adds value, or whether an authorization from the principals in the Resolution is sufficient? I am also considering whether we can use a separate authorized signer list with signatures as an appendix, rather than re-creating a signature card every time there is a signer added or deleted. Am I behind the times?

How to Verify Another Bank's Cashier's Check

12/27/2020

I am new to work in a bank and want to know if all banks verify the cashier's check the same way. If a non-customer walks into the bank and tries to cash a $180K cashier's check and asks for $5000 in cash and the remainder in a cashier's check, do I legally have to do this? And if they don't want to open an account do I have to cash it for them? How do we know when a check is valid, or if it has been altered or when it isn't as I haven't been taught how to verify another bank's cashier check?

Require Employees to have Acct. & Services?

12/20/2020

Can a bank require employees to have an account and services so that they can help customers with functionality? We do not require them to have their payroll deposited at our institution.

Withdrawals Over $10K from ATM-CTR?

12/20/2020

If a client withdrawals over $10K from an ATM machine over the weekend, Saturday and Sunday are we required to file a CTR on our client?

Foreign Check Returned 4 Months After Deposit

12/13/2020

We had a foreign check returned to us from the clearing US bank. The date of deposit was June 11 and we are just getting it back more than 4 months later. Are we able to refuse this?

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Exemptions for Escrow Accounts for Higher Priced Mortgage Loans

by Nancy Castiglione, CRCM

HMDA Reporting Exemption

Question: We have a question about the correct way to calculate the number of loans to determine whether we are exempt from reporting under HMDA.

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Most Popular Compliance Content

Joint Overdraft Guidance: Extension Past 60 Days?

01/31/2021

I understand the Joint Overdraft Guidance states that overdrawn accounts should be charged off after 60 days. Is there anything that would allow for an extension past the 60 day mark? (i.e. a fraud investigation, pending transactions, approval from upper management, etc.)

Reg E and Tier Three Timely Notification

01/24/2021

Regarding Reg E and tier three timely notification: if a cardholder submits a dispute stating fraud occurred 5/1/20, our institution would apply the tier three timely notification and deny items beyond that statement + 60 days. If that same cardholder comes back after this dispute processes, and claims additional fraud on the same card dating back to 1/1/20, are we allowed under Reg E to re-evaluate that tier three application? Additionally, if the cardholder makes separate claims on two different days (consecutive days for example) is it correct that we may treat that as a single claim?

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