John began his banking career in high school when he started as a teller at a $15 million bank that didn't have account numbers for its checking accounts (he says they actually filed by signature!) He moved to Cape Cod Bank and Trust Company in 1971 and assumed the position of Compliance Officer in 1976. He also served as corporate secretary and secretary of CCBT's Board of Directors, and as clerk of the bank's holding company.
He was a member of the Massachusetts Bankers Association Legal and Regulatory Compliance Committee, and of the American Bankers Association Compliance Executive Committee and NCS/NGCS Advisory Board. He is a regular presenter and participant in BOL Conferences events.
You may contact John via email at jburnett@bankersonline.com.
09/17/2023
Can we store digital copies of medical payments processed through a lockbox to meet record retention requirements for HIPPA or do original physical documents need to be kept? We are using the 10 yr retention schedule currently; assume that is correct?
09/17/2023
Customer A and Customer B (a married couple) open two single-owner CDs with cash. Customer A's CD is opened with a CTR-reportable amount of cash. Customer B's CD is opened with $5,000 cash. Would Customer B, Customer B's CD, and the cash used to open Customer B's CD be included in the CTR?
08/27/2023
Are signatures required on the Beneficial Ownership Certification Form? We don't get those forms back from a lot of customers. The person opening the account will supply the information of the actual owners, but often fail to return the signed form.
07/30/2023
When will the Interagency Guidance on Third-Party Relationships: Risk Management document become effective?
07/23/2023
Can we shift responsibility for safety and soundness to a third-party service provider in our contract with them?
07/23/2023
We have a non-banking client who received several checks from his deceased grandmother (our client) which total over $10K. He is traveling from KS to Fla to cash these checks. Our problem is that he doesn't have a Social Security Number. Can or should we cash the checks and create a CTR, or refuse him? He does have a DL. He lives off the grid....we will file a SAR for sure.
07/16/2023
Are the areas addressed in the Guidance limited to laws and regulations addressing fair lending and prohibitions against unfair, deceptive or abusive acts or practices?
07/16/2023
An executive officer has a debit card transaction that has caused an overdraft. As to Reg O, we would pay and charge the fee. But as to Reg E he has opted out which means we would pay the item and not charge the fee. I don't know which Reg takes precedence. The account is overdrawn less than $100.
07/09/2023
Does my small community bank need to adopt the same third-party relationship risk management approaches as larger, more complex banking organizations?
07/02/2023
Can the details provided in the Guidance with respect to the aspects of the risk management life cycle be used as a check list for my bank’s risk management plan?