Most Popular Compliance Content
Birthdates for Loan Applicants
02/16/2004
I read the response to the question titled <a href="http://www.bankersonline.com/compliance/gurus_cmp100603m.html">"CIP and Birthdate Info on Loan Apps"</a>, and I have a further question. Under 326 we are required to get DOB for all new accounts including loans. If we collect DOB on loans we may be in violation of Reg B. Which rule should we be following?
Impact of an Elevation Certificate
02/16/2004
If a borrower receives an elevation certificate from an surveyor that a property is not in a flood zone, is that sufficient to not require flood insurance?
FinCEN Advisories and OFAC Sanctioned Countries
02/16/2004
Do you have an updated list of the countries with FinCEN advisory warnings? Also, do you have a list of OFAC Sanctioned Countries? We have an OFAC Compliance program, but I would like to send a bulletin to all departments listing these countries.
Timing for Hold Notice
02/16/2004
We had a situation recently when a customer sent a relative to make a deposit into their checking account. The deposit had a large out of town check in the deposit. The teller neglected to place a hold on that item at the time of deposit; however, I thought we could send the hold out within 24 hours, since the person making the deposit was not on the account. Another employee disagreed, stating that the deposit was made in person, therefore the funds availability hold notice should have been given at the time of deposit. What is your opinion?
Automated File Transfer for Cash Management Services -- Tumbleweed
02/16/2004
We want to offer our corporate and commercial banking customers the automated cash management services that big banks provide to their most valuable wholesale customers. Since FTP doesn't meet GLBA and other regulations for privacy and auditing, how can we automate the file transfer process and provide electronic payment and reporting services to our customers?