Customer requests $35,500 from his 5 credit cards. Each card is approved and authorized by credit card company. At the same time he placed the funds in his checking account with us. After completing transaction, he requested the branch manager to withdraw the same amount and cut a bank check payable to a business. Question: Do you feel a SAR should be filed? The issue is being debated between our Compliance and Bank Security officers.
If an individual has a loan secured by business real estate as collateral instead of personal real estate, would the bank be required to send a 1098 and report the interest?
We are providing change in terms on prematurity notices for our CD customers. The TIS is rather generic, but does contain all the required elements. The top of the notice contains the specific maturity date and number to call to find out the rate. We are trying to combine all like CDs by type code and hard coding the system with the TIS prematurity info. My concern in so doing is lumping the variable and fixed rate CDs on the same prematurity notice. All the terms are the same except for the fixed vs the variable rate feature and this feature is not one of the change in terms. Do we need to state somewhere in the prematurity notice the fixed vs variable rate feature even though it was disclosed on the original account opening CD?
Management wants to reduce paperwork by creating one application for many bank products. They want to take the application for checking, savings and ready cash accounts and add blanks for HMDA reporting data on the back of the application so it be can used for loan applications as well. The instructions on the back will state the HMDA reporting information is to be completed by creditors only. Are there compliance issues that we should be concerned about?
Reg O: If a loan is made to a spouse, under their own signature and taxpayer ID, is it an insider loan?
For Reg O purposes, do insider loans include loans made to relatives (especially spouses) under their own signature and taxpayer ID?