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Latest Compliance Topics

Lottery Exceptions

06/16/2024

Now that banks can participate in lotteries, can we facilitate raffles unrelated to the bank for local service groups, posting lobby posters or selling tickets for or be a sponsor, etc.?

Reporting winners to the IRS

06/09/2024

We ran a contest and no prize was over $300. We didn’t need to collect non-public private information from the winners since the prizes were small, did we?

A bake sale by any other name

06/02/2024

Every year we hold a bake sale to raise funds for Breast Cancer Awareness/Local Hospital Foundation. Is this acceptable?

Need training materials on Regulation GG

05/26/2024

I am looking for ideas for training materials on Regulation GG. Also, does Regulation GG only apply to a commercial business that may be using their account as access for internet gambling?

Was this check altered or forged, and why does it

05/19/2024

Our customer issued a check to an insurance company. The item was altered (washed), made payable to a new payee, and deposited into that payee's account. We were outside of the 30 day return window and went bank to bank to recover the funds. We are being told that our claim is being denied due to the following: "The check contains a forged maker signature. This is not an altered item and there is no breach under UCC § 4-208. Our review of other items involving this drawer demonstrates that this check was not signed by an authorized signer of the drawer. As a result, we decline to pay the claim." How would they as the depositary bank be in any position to tell us that our customers signature is forged? It was not forged. The payee line was altered. What are our rights to refute their denial so that we can reclaim the money?

What changed on Reg CC Exams

05/12/2024

I see from the BOL Daily Compliance Briefing that the FDIC Exam Manual has been updated. Specifically it was noted, "Expedited Funds Availability Act (VI-1.1): Updated with technical changes related to regulatory dollar-amount thresholds and large deposit hold times." I've compared the old and new versions of the part of the Reg that is referenced and am hoping someone can point out to be specifically what has changed and what the new expectations are from the revision? I don't know that it will change our process because we already make funds available a little earlier than required in most cases and our disclosures accurately state this, but I want to be sure.

Digital Signage Requirements

05/05/2024

The new FDIC Official Digital Sign requirement has a specific wordmark size that is not format friendly when displayed in mobile banking. Can the sizing be adjusted for the screen or must the text be wrapped for full display? Will resizing to accommodate the screen impact compliance?

MSB, But Not at our Bank

05/05/2024

If our institution banks an entity that is registered as an MSB but, the entity does not hold their MSB account at our institution, are we still required to complete a full MSB high risk review or even have them marked as an MSB?

BSA - Logging Cash Advances

05/05/2024

Should you log a cash advance to the BSA log after the cash advance was used to purchase a Cashiers Check? No money was exchanged.

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Consumer Protection for mistake in loan payment transaction

08/25/2024

Scenario: A bank employee inadvertently makes an error while processing a payment authorized by phone by the customer, for example, customer authorized his/her personal loan monthly payment of $100 but the employee processes a debit for $101, or $96. Could this be considered an unauthorized electronic fund based on the amount error? Can this be considered a violation of other consumer protection law/reg? UDAAP?

Records retention and canceled remittance transfer

08/18/2024

Regarding a cancellation request of a consumer foreign remittance transfer - are there any document retention requirements related to the canceled wire transfer request? Is the FI required to retain a copy of the wire transfer request form or any other documentation related to the transaction since it never occurred if canceled within the 30-minute window? Our bank has a log to record all canceled international wire transfer requests, but that is the only documentation.

Completing CTRs on a business account

08/18/2024

When filing a CTR on a business deposit, do you include everyone on the account like you would a personal CTR or just the actual conductor?

Recognizing recurring and non-recurring debit card

08/11/2024

Can a merchant force a debit card transaction by claiming that the transaction is a recurring transaction event though it's not? For example, the customer opted out of overdraft service for ATM and one-time POS debit card transactions, but a merchant forced the transaction by claiming it's recurring.

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