Most Popular Compliance Content
SCRA and the Interest Rate Reduction Requirement
10/18/2004
I have been reading the Servicemembers Civil Relief Act and I am confused about when the reduction in the interest rate should take place and who should initiate it. If the financial institution is aware of a member's active status after the loan commitment, should it automatically reduce the rate, or should the institution wait for the member to contact the institution?
Account Styling SSN vs EIN
10/18/2004
If a sole proprietorship account is styled Jane Doe dba Jane's Jeans, we would use Jane Doe's SSN for the tax ID. If Jane's Jeans has its own EIN, should the account be styled the same? I always understood the first name on the legal title should match the tax ID number.
Steps in Changing the Fee for a Safe-Deposit Box
10/18/2004
Can you tell me what the requirements are for notifying customers when there is an increase in charges for safe-deposit boxes? Are there rules stating how much notice we must give customers about such changes?
Exempt or SAR this Commercial Customer?
10/18/2004
I have a commercial (restaurant) customer who has an on-site ATM. He regularly gets cash to fill the ATM, between $6,000 and $10,000, but never going over that. He sometimes brings in additional money for change. I believe that we should have this customer on our exemption list, but I also believe that the reason he never goes over $10,000 is to avoid a CTR. Our compliance officer said we did not need a SAR because we know what he is doing with the money. We are confident of this. If we know that he never gets more than $10,000 to avoid the CTR, that would qualify as structuring, and should trigger a SAR. Should was file a SAR or have the account exempted?
UCC and Legal Names
10/18/2004
I listened to the recent "Common Mistakes in UCC Filing" Webinar. In the materials it states to use the debtor's EXACT full legal name. Should punctuation be used in cases of periods and/or commas? Examples: Big Corporation, Inc., or Big Brothers, L.L.C. And what about hyphens (-) that are part of the name? When we request a search (we use SOS Direct) for debtor names, the punctuation doesn't appear on the search report. Should we be searching the names "with" and "without" punctuation?