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#1796200 - 03/19/13 04:07 PM Business activity in accts classified as consumer
Tryin-2-Comply Offline
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Joined: Apr 2003
Posts: 202
Hills of TN
How do you handle accounts that are classified as consumer checking accounts, but the customer is clearly conducting a business out of the account?

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#1796210 - 03/19/13 04:20 PM Re: Business activity in accts classified as consumer Tryin-2-Comply
rlcarey Offline
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rlcarey
Joined: Jul 2001
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Galveston, TX
Tell them to open a business account or you will close their personal account. What other options are there?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1796249 - 03/19/13 05:26 PM Re: Business activity in accts classified as consumer Tryin-2-Comply
Tryin-2-Comply Offline
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Joined: Apr 2003
Posts: 202
Hills of TN
The loan officer or account officer - telling me that's not happening.

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#1796253 - 03/19/13 05:28 PM Re: Business activity in accts classified as consumer Tryin-2-Comply
MrsSmithCRCM Offline
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MrsSmithCRCM
Joined: Dec 2012
Posts: 169
Here for the moment
One thing you can point out to those people are that when you disclose to a consumer account- you disclose Reg E, and that you are thereby extending Reg E protections, so when these corporate ACH transactions post, you could take a loss. Beyond that, anyone in your "chain of command" that could help? Another issue is accepting for deposit business checks into a personal account- there are many issues here.

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#1796261 - 03/19/13 05:38 PM Re: Business activity in accts classified as consumer Tryin-2-Comply
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,293
It is important for banks to get these accounts into the proper categories (consumer or business) so that they are handled properly for AML (risk ratings, monitoring, risk assessments (how many accounts in what category) etc.)
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
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#1796302 - 03/19/13 06:37 PM Re: Business activity in accts classified as consumer Tryin-2-Comply
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
Also, the "loan officer" should not be making bank policy. As Kathleen suggested - take this to a higher authority.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1796824 - 03/20/13 08:37 PM Re: Business activity in accts classified as consumer Tryin-2-Comply
Becky Offline
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Becky
Joined: Feb 2003
Posts: 216
Dallas, Texas
Also, let the Officer know you could be losing some fee income. With the daily max on NSF fees in consumer DDAs, you may not be getting the opportunity to charge for the full number of presented NSFs that you could on a commercial account.

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#1796855 - 03/20/13 09:10 PM Re: Business activity in accts classified as consumer Becky
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Quote:
The loan officer or account officer - telling me that's not happening.


One of the banks where I worked had a great policy: If an officer wanted to give instructions to someone who was not a direct report she had to talk to her peer in that area. If I was a VP of lending I would have to go to the VP of operations to give an "instruction" like that. It stopped this kind of garbage...
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