Most Popular Compliance Content
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?
Use New Red Flag Checklist on All Customers?
09/01/2008
Is the new Red Flag checklist to be used on all new customers or on existing customers that have a loan that is renewing?
About the Verifying Address Requirement
08/29/2008
Would the verifying address requirement apply to an existing customer obtaining a new loan where the bank obtains a new credit report that shows an address discrepancy?
Separate Policy - or Amendment of FACT Act Policy
08/28/2008
Are the regulators wanting to see a separate policy...or can we amend our current FACT Act Policy to include the Red Flag and Identity Theft Policy Requirements?