You can reach Randy via email at: careyrandy@comcast.net
10/17/2021
If a customer presents a military identification card and has no other form of ID, it is my understanding is you cannot make a copy of Military ID's. What other forms can be used? This person does not drive and has no transportation to get to the DMV. He does have an expired TX DL but that is all.
10/10/2021
Is it legally permissible to email a firm offer of credit?
10/10/2021
We received a call from a credit union on 9-1-21 informing us that a cashier's check on them was fraudulent. We sent that check out on 8-5-21. We waited 10 business days to give the customer credit. (8-20-21) The customer has spent more than half the funds but I placed a hold on the remaining amount. Do credit unions not return through the Fed like banks? They sent us an Indemnification Agreement to sign and send the funds back. Could this be considered a Late Return? Help!
10/10/2021
Our bank is now charging a $3 fee on paper statements in an effort to move everyone to online banking, where there would be no charge for the statement. Is this permissible by Reg?
10/03/2021
If a residential ARM loan does not have a rate change, and therefore, does not have a payment change, is the bank still required to send the ARM notice?
10/03/2021
If a mother allows her son to use her debit card and PIN, then another day the son takes the card and withdraws cash from the ATM (which we have video of him) and the mother does not want to press charges, does she have dispute rights? Can we the bank require the police report in order for her to make a claim? She says he does this all the time and he lives with her.
09/26/2021
We are refinancing several mortgage properties for the same consumer at the same time. Can one credit report be pulled and used for all refinancing loan files? This provides a cost savings as we only charge for the one credit report.
09/26/2021
When an account requires two signatures to be present before the check is honored, how can the bank verify or allow an account like this to have ACH debit transactions or checks that have been converted into an ACH transaction? The bank does not want to be held liable for something like this if the two signatures are not available to verify.
09/19/2021
I have a customer that appears to be processing personal transactions through his business account with FanDuel internet gambling site. FanDuel operates under a specific exemption written into the Unlawful Internet Gambling Enforcement Act of 2006 (UIGEA) that allows for fantasy sports contests. Am I correct in thinking that the use of FanDuel is not a violation of Reg GG? Also, is conducting personal transactions through a business account SARable?
09/19/2021
I received a cash deposit for $15,010.45, and of course, had to file a CTR. I filed it for $15,011, but my BSA officer said it should have only been for $15,010. I thought we were supposed to round up to the next dollar, which is correct? By the way, that was the only cash that this customer brought in for the day.
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