Tailored approach to risk management
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?
John Burnett joined Glia Group, Inc., and BankersOnline in 2004, and currently serves as Executive Editor. He is a 1990 honors graduate of the Stonier Graduate School of Banking and is an alumnus of the ABA National Compliance School, where he served on the faculty for several years.
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 of BOL Learning Connect webinars and a participant in BOL Conferences events.
You may contact John via email at jburnett@bankersonline.com.
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?
07/02/2023
We were having a discussion this morning at our Compliance Meeting about raising the limit of our POS for our debit cards. Currently, we have it set to $500 and were thinking about raising it to $750 or $1,000. If we would raise the limit to some other amount, would the bank's liability increase? If there is anything you can tell us to reference we would appreciate it.
07/02/2023
When an applicant emails a mortgage loan application, when it is considered received by the bank? When does the disclosure clock start to run?
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?