Most Popular Compliance Content
FinCEN Advisories and OFAC Sanctioned Countries
02/16/2004
Do you have an updated list of the countries with FinCEN advisory warnings? Also, do you have a list of OFAC Sanctioned Countries? We have an OFAC Compliance program, but I would like to send a bulletin to all departments listing these countries.
Timing for Hold Notice
02/16/2004
We had a situation recently when a customer sent a relative to make a deposit into their checking account. The deposit had a large out of town check in the deposit. The teller neglected to place a hold on that item at the time of deposit; however, I thought we could send the hold out within 24 hours, since the person making the deposit was not on the account. Another employee disagreed, stating that the deposit was made in person, therefore the funds availability hold notice should have been given at the time of deposit. What is your opinion?
CIP and Savings Bonds
02/09/2004
Do we need to verify identity under our CIP procedures for a customer purchasing or redeeming US Savings Bonds?
Recission Rights Upon Modification
02/09/2004
I have a matured real estate loan that I am going to modify the payment amount and the maturity date. I intend to leave the accrued interest as is, as well as the late charges that have accrued on the loan. Do I need to give the customer a right of recission, since this is their primary residence?
Signature on Adverse Action Notice
02/09/2004
I have reviewed Regulation B to see if and Adverse Action Notice requires a signature on the document to meet the requirements of compliance and auditors. We do put our bank information, address and phone #, but the partiy that completes them has not being signing the form.