Most Popular Compliance Content
Completing CTR Correctly on Check Cashing
05/03/2004
My question is on filling out a CTR. My bank has several business customers who cash checks for their customers. Due to this activity, several times a week they send in an employee with a check (ususally over $10,001) drawn on the business and made out to cash. The employee is the one who walks out with the cash and we assume that the employee is taking that money back to the business. Should we be filling out the CTR section A on the business (making the assumption that the business is benefitting) and put the employee in section B, or fill out the CTR section A on the person who comes in and actually receives the funds even though we think those funds are being used for the business to cash checks? Or even another scenario...filling out section A for both business and employee? Would it make a difference if there was a notation on the check stating "check cashing" or something we might use to know that the funds were going back to the company for use? Wehave debated all ways and wondered what the gurus thought.
Putting Bank's Charter Number on Flood Form
05/03/2004
Is it necessary to put the bank's FDIC charter number on the Flood Determination Form in the box for Lender ID?
Referral Fees for Commercial Referrals
05/03/2004
Is is illegal to pay a referral fee to a bank employee for a commercial referral?
Making Regulatory Burden Worse
05/01/2004
Sometimes we are our own worst enemies. The Regulation B signature rule changes is precisely such a situation. What happened was we asked questions.
SAR
05/01/2004
Question: We are having a debate about whether to file a Suspicious Activity Report on a customer. He is a foreign national who has several business accounts with us.