If a consumer leaves a voicemail stating name and account number and that there are a couple Amazon charges on their account that are not theirs, is that a valid notification of claim? Sometimes we cannot get back in touch with a member and if they didn't state specifically a date and amount does this still start the investigation timeclock?
What if the customer says that they don’t have a PayPal account? And they don’t know how PayPal got their information, can you deny the claim and have them contact PayPal?
When we receive a pre-arb for a fraud transaction that shows proof of delivery to the address on file, the tracking info just shows city and ZIP for it being delivered. But when the member went to the post office to get more info, it shows it was delivered to a different address in their neighborhood. Any advice on how we should proceed with these pre-arb responses if we do not have the ability to get the post office info to get the exact address?
Can you explain a late claim and the process that needs to be taken?
What is demonstrable consent and can we do that with new account disclosures we email the new customer?
Can a customer cash a check on a DBA/Sole Prop account if the check is made out to the business?
We have a CTR dilemma. A customer came in with $20,000 cash.
- The funds were first deposited into his account.
- He then wanted to purchase a cashier check for $7,000.
- He returned later the same day with an account number of a family member and wanted to transfer $18,000 using the cash deposit and preexisting funds from his account. He is not on the family member's account.
The reason stated was that they are in the process of buying a house and escrow wanted him to show the proof of funds in a statement which was the reason for the transfer. How would you complete the CTR in this situation: is there only one Part 1 (customer) or two Part 1 (customer and family member)? And the $7,000, would be under negotiable instrument and $13,000 under fund transfer?
We also plan on filing a SAR.
FIN-2021-A002 and FIN-2020-A007 describe Unemployment and Economic Impact Payment Fraud that financial institutions should be aware of. However, the economic payment amounts and most unemployment insurance amounts are below SAR reporting thresholds. Is there a requirement to look for and file a SAR for these types of fraud even if the amount is below the SAR reporting threshold?
Can you go over the Reg E disclosure given to businesses? What is their liability?
I am new to compliance and looking for assistance in creating a compliance program for the credit union I work for. We are a small CU and a dedicated compliance officer role is new here. Would appreciate any help or guidance you can offer.