01/28/2024
When a customer has joint account and only one person on the account wants to add a beneficiary to the account, can this be done or must each accountholder agree?
01/28/2024
We have a business customer whose deposit runners are refusing to provide their information for us to collect as conductors of cash transactions. These are typically smaller transactions, but we require a conductors information on all cash transactions over $1,000 for aggregation reporting purposes. They previously banked at a larger regional bank which did not require these runners to provide identifying information. Are we OK to make an exception for this business client unless it is a CTR reportable transaction?
01/28/2024
We have a customer that is an agent for one of the local insurance companies. She wants to open an account in her name only using the insurance company EIN, can we do that?
01/21/2024
I have a CTR question I have yet to see posted anywhere. Any cash
transaction(s) more than 10K to a joint account by any conductor is a CTR. However, what if there are multiple (3) joint accounts. EX: $5,000 cash deposit by Suzy to account A; $5,000 cash deposit by Suzy to account B; $1,000 cash deposit by John Doe to account C. All 3 accounts are jointly held by the conductors. Would this be considered a CTR because Suzy and John can benefit from the $11K, via separate accounts or exempt because not more than one person conducted to a single (one) joint account?
01/21/2024
We recently inquired if we could use self-deposit investments where the bank is acting as Trustee. We have received a legal opinion stating that we can use self-deposit investments so long as we document our due diligence, the trust allows for the investment, and our Money Market Account (MMA) is a competitive rate.
We are currently discussing a referral incentive program which would include our Trust Division. I have read a lot of guidance between FDIC, OCC, and FRB, but I am not seeing anything that speaks to my particular situation.
Can a Trust Officer use a self-deposit investment as Trustee and still receive a referral incentive for this transaction? I personally feel like this is a conflict of interest and somewhat, self-dealing. However, I am not seeing anything stating this would be an issue per se. I am only running into nonretail deposit and broker/dealer requirements.
I have also looked through Arkansas code (our state) and I could not see anything that spoke on this particular situation.
If you have any insight or could point me in the right direction to help confirm or rebuttal my though process, I would really appreciate it!
01/21/2024
What are your thoughts on allowing customers to give an authorized signer access to their online banking and/or approving them to have a debit card? Would it make a difference if there is a form signed by the customer providing authroization and acceptance of liability for the transactions the signer conducts?
01/14/2024
We are promoting a CD special on social media. The Reg DD advertising disclosures are a drag. Must we include them? Can’t we say something like “call us for details”?
01/14/2024
Is a check payable "FOR" someone the same as a Representatives Payee? I've seen checks that do not have "Representative Payee for..." just "For..."
John Doe
FOR Sally Doe
Is this sufficient, or what should it read?
01/14/2024
I am working with a new core system and we are discussing our exceptions process for items presented that cannot post for various reasons i.e. NSF, closed account, account restriction, etc. This system will not backdate the item to the date of presentment in cases where we choose to pay it. Is there anything that states the item must be "paid" on the date of presentment?
Every other core I have ever used in my 28+ years has always backdated the item to the presentment date.
01/07/2024
Can we waive early withdrawal penalties on CDs?