Latest Compliance Topics

Disclosing the Military APR

02/28/2021

Do we have to disclose the actual MAPR to all borrowers?

Printed Disclosure by Mail?

02/28/2021

If a customer requests a remittance wire transfer while in the bank, but then decides they can't wait for the printed disclosure, can they leave and we provide the disclosure to them orally, provided we send them the receipt by mail?

Are CSR emails to customers "ads?"

02/28/2021

Does CAN-SPAM apply to those emails sent by platform employees to let their preferred customers know of new rates, etc.?

Felony Moments and BSA

02/28/2021

If the customer asks me a question on structuring is that reportable on a SAR?

Custodianship under the UTMA

02/21/2021

If a minor has funds in a custodianship under the UTMA but also has an individual account in his own name, and he has reached the age for release of the UTMA funds, can we use the funds in the UTMA to offset an overdraft in the individually-owned account?

Emailing who?

02/21/2021

Is CAN-SPAM limited to emails to consumers?

Attempts and SARs?

02/21/2021

If the customer attempts mortgage fraud should we tell BSA?

Military lending and major problems

02/14/2021

What’s the most severe penalty for a military lending violation you’ve seen?

Board of Directors Question

02/07/2021

If a credit union board holds a board only meeting after the normal Board meeting, must the Board Chair prepare special minutes or can they provide notes to add to the regular Board meeting minutes?

"Sporting Pools" and FinCEN/SARS

02/07/2021

Some taverns/bars are involved in "Sporting Pools" aka: Football Pools, Office Pools, Super Bowl Pools, etc. Does FinCEN encourage SARs to be reported for a business involved in such activity? Gambling is not legal in my area.