Most Popular Compliance Content
Reg D - Close Account Due to Excessive OD Activity
09/01/2008
A customer has excessive savings account activity due to overdraft coverage to a DDA account. Are we required to close the account per Reg D after making the customer aware of withdrawal guidelines and continued excessive activity, or can the account remain open?
Red Flag Program -- Service Provider Arrangements
09/01/2008
by Russ Horn, CISA, CISSP, CoNetrix
Refusal to Cash Non-Customer Savings Bond
09/01/2008
Are there any compliance violations if we turn away a non-customer who wants to cash a savings bond?
Policies and Procedures Manual for Red Flag Compliance
09/01/2008
What is the Policies and Procedures Manual for Red Flag compliance?
Date of Deposit Causes Reg D Violation
09/01/2008
When we monitor our customer's accounts for Reg D violations, can we use the check date on third party items as an indicator for violations? As an example, our customer wrote three checks in May. His third check didn't clear until his June statement which caused him to go over the limits in June. He had already written his three monthly checks for June, but didn't know that one of his May checks was still outstanding. His payee didn't deposit the check until June, so four ended up clearing for that 30 day period in June. He has no control over when his payee will deposit his check, but it puts his account in violation. As long as we treat every account the same way and verify every check date for transit items, would we be following Reg D?