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.
06/03/2002
Can MMDAs be monitored for excessive transactions on a calendar month versus the account's statement cycle? For example, a particular MMDA cycles on the second Tuesday of each month but our excessive report looks at activity from the first day of a month through the end of the month?
06/03/2002
For Reg P purposes, is it ok to send out annual disclosures as a statement stuffer (provided you meet the definition of "clear and conspicuous") and deliver it to all customers?
06/03/2002
We would like to know why we cannot put an exception hold on a credit card check or a insurance draft. A credit card check is truly a request for credit and an insurance draft is not a check. These checks have restrictive endorsements. We just participated in a Pegasus phone seminar and the gentleman replied that the Reg states that we cannot put a classification on a specific type of check.
06/03/2002
When would we use FTC's Notice "Preservation of Consumer Claims and Defenses" and where do I find the regulation on this?
05/20/2002
What is the UCC Code on the time frame for a forged/improper/ missing indorsement? I was told that it was three years after the date of the endorsement. I can't seem to find it in the bank law book. Do all of the above apply to the 3 year time frame?
05/20/2002
We have opened an "non-traditional" banking facility that serves the Latino community. We are requiring that the new customer provide us with either a SSN or ITIN or attest that they have applied for same when opening a non-interest bearing account. I have been met with some resistance. Where can I find the requirement other than our Know Your Customer Policy, Money Laundering Policy and BSA Policy that makes this a federal requirement that banks absolutely must have Tax ID numbers on all accounts?
05/20/2002
Isn't it true that we need to have the ID's, Social Security numbers and addresses of the signors on a business account to be compliant with the changes for BSA?
05/20/2002
What rights do we have to close an account if the balance has been at a zero balance. How many days does the account need to be at a zero balance before we can do anything?
05/20/2002
Regarding the Right to Rescind on refinance transactions: Is the "Confirmation Certificate" section of the form indicating the borrowers do not wish to rescind required to be signed by the borrowers?
05/20/2002
<a href="http://www.bankersonline.com/regs/229/22912.html">12CFR229.12</a> refers to the availability of funds hold. It does not specify the time of day that the hold expires. We have found conflicting answers so I need a citable source.