Most Popular Compliance Content
Rollover IRAs and CIP
04/18/2005
Automatic Rollovers and IRAs - CIP implications. There's a footnote on page 5 of the guidance issued under IRS Notice 2005-5 regarding automatic rollovers. CIP compliance on the IRA seems not to be immediately required at establishment when it is an automatic rollover, and says that institution will not be required to implement its CIP until the former employee first contacts such institution to assert ownership or exercise control over the account. Industry wide - any guidelines on what to do if the "account owner" never asserts ownership or whether within a certain timeframe after account establishment you become responsible to find them to secure CIP requirements? (I don't exactly trust the footnote) I envision accounts established for "lost participants" who I will be hard pressed to fulfill my CIP requirements.
Not-for-Profit vs. Non-Profit
04/18/2005
We are trying to institute difference between not-for-profit accounts (club, association, leagues, groups) and non-profit accounts (churches, boy scouts, girl scouts, etc). How do we differentiate between these two types. Some organizations are filed at the Secretary of State as non-profits and we thought they would fall into our "not-for-profit" account. We would appreciate some help.
Reg. E Error Resolution Notice
04/18/2005
We have the Regulation E Short error resolution notice on the reverse of our statement paper. We do not send an annual notice to our passbook account holders. Passbooks may receive a Direct deposit. Are we required to send a separate annual notice to these customers? Our auditors say we are. I thought passbooks were exempt from the periodic statement requirement and that the short Reg. E notice on the statement could be used in lieu of an annual notice.
Payable Through Check - Local or Not?
04/18/2005
I was reading a response to a question regarding a hold on an insurance draft or credit card check. I want to make certain that it is OK to put an exception hold on this type of check, if over $5000, release $100 next day, $4900 in 2 or 5 days and the balance over $5000 in 7 or 11 days. What started my search was I was trying to determine if I had a "credit union" cashiers check (local), payable through a (non local) bank, which routing number do I use to determine the hold?
Notice Requirement to Eliminate Saturday Banking
04/18/2005
We are considering closing a branch on Saturdays only in a small local community. We would like to know the amount of days if any that we have to give our customers. Also will we have to do a special mailing. I do not know if you need this information, but the branch has an outside ATM and it is the only bank in the community. The next closest bank is ours at 12 miles away.