Most Popular Compliance Content
State Agency Investigation - RFPA Applicable?
05/18/2009
The bank has recently received a subpoena for one of our customers. The investigation is being conducted by state agencies. Does the federal version of the Right to Financial Privacy still apply? Do we still need a letter of compliance and does the bank need to wait for the customer to contest?
Merchant Services Application/Agreement
05/18/2009
Must a merchant services application/agreement have a separate document or separate authorization that must be signed in order for the merchant processor to pull a credit report on the principals?
Decreasing Early CD Withdrawal Penalty
05/18/2009
If we decrease the early withdrawal penalty on our Certificates of Deposit do we have to disclose this to our customers? I was told that if a change benefits a customer in a positive way that re-disclosure is not required.
How to Implement Risk-Based OFAC Monitoring Practices
05/18/2009
How to Implement Risk-Based OFAC Monitoring Practices
Five steps to risk assessment; ten practices for monitoring
by Timothy R. White, CAMS
Credit Report Authorization Form Retention
05/18/2009
I am filling in for our bank's compliance officers while they are away at training. A co-worker posed the following question/situation and I have been unable to find the answer after some research. Our bank does credit checks/counseling for customers and non-customers. We have a form signed authorizing/permitting us to pull credit reports on the individuals. How long are we required to retain the authorization forms?