What Goes in a CRA File?
09/22/2003
I have just taken over the CRA file for our bank. I've never done anything with this before. What goes in the public file? Should I keep an examination file? Any help would be appreciated!!!
Mr. Andy Zavoina, CRCM, is an Executive Vice President and Chief Relationship Officer with the Glia Group, Inc., best known for its interest in BankersOnline.com. He joined Glia and BOL in 2003.
Mr. Zavoina has been in finance and banking for 42 years. Over 20 years were with a two-bank holding company which had $534 million in assets, 89 branches spanning Texas and nearly 500 ATMs. He managed loan workouts, has been a consumer, commercial and real estate lender, managing those departments, as well as being his banks first Webmaster. He was responsible for compliance -management, -auditing, and -training for both banks.
Andy is a frequent webinar presenter for BOL Learning Connect and a key contributor to conferences put on by BOL Conferences, Inc. In addition, Andy teaches live presentations at state association schools and regional compliance organizations across the U.S. and has served on the faculty of national banking schools. He has written articles and lectured on many facets of compliance, the use of the internet and technology as a tool, as well as compliance in cyberspace.
As a BankersOnline Guru, Andy assists banks in every day, and not so every day, compliance questions on BankersOnline, BankCompliance.com and other organizations.
Mr. Zavoina is a recipient of the American Bankers Association’s Distinguished Service Award for his involvement and accomplishments in the field of regulatory compliance management. He is a past Chairman of the ABA’s Compliance Executive Committee, the Editorial Advisory Board for the ABA Compliance Magazine and served as a member of the ABA’s Compliance School Board. He also served on the Texas Bankers Association's Compliance Committee.
He is a graduate of the ABA National Commercial Lending School, National Compliance and National Graduate Compliance School and is a Certified Regulatory Compliance Manager with the Institute of Certified Bankers.
You can reach Andy on the Internet by using his e-mail address, andyz@bankersonline.com, or visiting http://www.bankersonline.com.
09/22/2003
I have just taken over the CRA file for our bank. I've never done anything with this before. What goes in the public file? Should I keep an examination file? Any help would be appreciated!!!
09/15/2003
I was wondering if Compliance Officers, who are involved in management, are allowed to have access to the vault. I'm not sure about this issue, however, I believe that a Compliance Officer should not have "direct" access of the vault key/combination. They must go through another officer/manager first. Right?
09/15/2003
Is there a statute or regulation that still specifically requires us to stock teller drawers with bait money, or is entirely optional?
09/15/2003
A customer brought us checks which represent a redemption of trust accounts in his children's names. They are payable to the trustee (father) and he wants them deposited to his own personal account. We have no trust papers. What is our responsibility?
09/15/2003
There are several banks in our state that are refusing to cash checks drawn on their bank for non customers. Can they do that? I have been asked if we can do the same?
09/15/2003
During a recent audit of our now account files, we came across a sole proprietorship whose file was missing several necessary items. The only item in the file is a small banker's system signature card. The card contains the customer's signature, account number and date opened. The account was opened in 1974. We sent the customer a new signature card and sole proprietorship resolution form to fill out and return to the bank, however, the customer refuses to sign the new forms stating he doesn't like something within the account agreement. He does not recall what that was but insists he will not sign. What can we do?
09/15/2003
With respect to the Soldiers and Sailors Civil Relief Act (SSCRA), I understand debts incurred prior to entry into the military are subject to the 6% interest rate cap. Does it matter whether or not the military member voluntarily enlisted in the military? I thought the SSCRA would apply only if someone was drafted into the military.
09/08/2003
There have been numerous threads regarding CIP policy versus procedures. Some threads state that the CIP procedures need to have Board approval whereas others say a general overview of procedures is needed. My question is 1)do the procedures really need to go to the Board for approval and 2) how in depth do these procedures need to be? Could we keep the policy separate from the procedures or do they really need to be a single document?
09/08/2003
In regards to the USA PATRIOT Act CIP provisions: For addresses similar to a P.O. box, such as AIM Mail Services, Mailboxes Etc. (now The UPS Store), Pak Mail, Parcel Plus, PostalAnnex, PostNet and others that essentially compete with local post office services (by providing private mailboxes), do banks have any requirement to try to identify these types of addresses? Would we need to request an actual residential address? (In reading the rule and its preamble, these would be considered as business addresses and may constitute compliance. However, these could also be a means for bad people to open an account without providing a true physical address. These companies extend their business street address to customers and assign a box or suite number. The result is an address that cannot be distinguished unless it is listed on a fraud file somewhere.)
09/08/2003
How should our CIP handle verification on retail contracts purchased from local retailers?