When preparing a SAR narrative, if the business account relationship contains multiples accounts (at least 8) and the suspicious activity was only detected on two, are we permitted place emphasis on those affected accounts and establish that none of the remaining accounts had flags or suspicious activity detected?
How are people finding out about customers who pass away if not notified by a family member?
For an ACH transaction we (RDFI) have received, we believe a third party made the payment to an account and we (as RDFI) would like to return it. May we return it using the return code R23? R23 description sounds as if the recipient account holder should return the transaction.
Can a POA add beneficiaries on an account?
Can a bank account be opened for an entity such as an LLC and a person i.e., JSmith Properties LLC and Suzy Sparkles? Suzy Sparkles is not a member of the LLC.
Does anyone have any suggestions for putting together a policy on how to handle customers using cell phones to take photos or record interactions within a branch?
If an account owner is a Trust, is it covered more by the FDIC insurance?
I have been trying to find what the requirements are for giving bonuses to open a new account. There are advertisements everywhere of cash offerings, freebies, or giveaways. We’re still stuck on the value of offer cannot exceed $10, however we see TV ads offering $300 to open an account.
What compliance issues do we need to address if our offerings go beyond $10? As an example, April is Teach your Children to save month. Marketing has come up with a campaign that if you come by and get a piggy bank and bring it back full of coin with your child and use it to open an account, the bank will also deposit $10 into that new account, or it could be an existing account.
Can a corporation sweep from a personal account? We say no but are checking what you think?
During account opening for a new business customer the branches verify that the required annual filings with the state are up to date. As new accounts are opened for existing business customers a CDD questionnaire is completed for each new account, however the branches are pushing back regarding verifying that annual state filings are up to date. I haven't been able to locate any guidance on whether this is a requirement or a recommended best practice. Can you please advise?