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#1262921 - 10/07/09 03:23 PM Reg GG Questions
Golfer9 Offline
100 Club
Joined: Sep 2007
Posts: 199
Oklahoma
Some questions about a Reg GG Policy:
1)ACH: muat we monitor or just take action if we observe illegal ACH activity? ACH receipt and origination?
2) Wires: again, must we actively monitor or only take action if csutomer is "receiving" a restricted item? Do we NOT post the wire and notify the customer?
3) Checks: If we notice restricted items being deposited, shoudl we deny the deposit and notify the customer?
4) Debit cards: Should these types of items be blocked if posssible thru our processor and if blocked should the customer be notified. If continued, should the card be cancelled?
What action does the legislation anticipate that the bank will take in the above instances?

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Operations Compliance
#1264271 - 10/09/09 10:57 AM Re: Reg GG Questions Golfer9
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
UIGEA (Regulation GG) does not require you to monitor anything. It indulges in the fiction that by obtaining customer certifications and providing customer notices you have prohibited the transactions from taking place.

If the fantasy bubble bursts and the customer receives a restricted transaction you are required to block (reject) that transaction.
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