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.
06/25/2023
Is a bank obliged to reimburse a consumer client for a fraudulent check paid out of their checking account? (We are in New Jersey.). Also, the client reported the fraudulent checks 10 months after statement cut which is deemed late according to our account agreement. I have not been able to locate a rule/code or law that makes us liable to a consumer for this.
06/11/2023
Are there any changes on how a single reportable deposit to a joint account is to be reported?
06/06/2023
How should we mark Item 3 to report multiple transactions?
06/04/2023
If our state allows spouses to jointly own and operate a sole proprietorship business without forming a partnership, will we treat a sole proprietorship account as a joint account when filing a CTR for a reportable transaction of the business?
06/04/2023
According to Reg D, "Savings deposit accounts are specifically excluded from the definition of transaction account, even though they permit third-party transfers, provided that the depository institution complies with the transfer and withdrawal limitations applicable to ‘‘savings deposits’’ under Regulation D." Since the Reg D transfer limitations have been lifted, does this now make a savings account a transaction account?
06/04/2023
Are banks required to exempt customers for CTR filing limits? I've worked for banks in the past that never exempted anyone. We just filed CTR's on large cash transactions. So in short is there a regulation stating that banks need to exempt customers, or why is it done?
06/04/2023
Regarding the new small business data reporting requirement expected to come out soon. Will this "1071" requirement be similar to HMDA and CRA whereby if it’s HMDA it cannot be reported as CRA? So if it’s a HMDA reportable loan, then we won't report it for the small business data?
05/28/2023
John Jones makes a cash deposit of $9,600 to the account of his hardware store, Jones Hardware, Inc. He also gives the teller five $100 bills and obtains $500 in $20 bills in exchange. Is there any change to how we will report these transactions?
05/28/2023
A client makes a cash in deposit of $8K. She also does a currency exchange for $5K. We now have a cash in for a total of $13K and a cash out for $5K. Is the $13K reportable since $5k is an even swap? I believe it is but I just need clarification.
05/21/2023
The CTR includes fields in Part I for “gender” (item 7), “contact phone number” (item 18), and “E-mail address” (item 19). They are not identified as “critical” fields. Do we have to ask for this information to complete the CTR?