Guru Emeritus - Thank you for lending your expertise to the BankersOnline.com community.
We have a restaurant customer who does not deposit cash to their account. They do however, exchange cash for $100 bills and then enter their safe deposit box. This customer has told a commercial lender that this is how they operate their business (it is an oriental restaurant), supposedly this is normal for this type of business. They also said they use the cash to go to a different bank and wire money to suppliers. It has become apparent they are having a difficult time closing the box and have rubberbanded it together to fit it back into the vault. Our question is whether this behavior in itself is suspicious and should we be filing a SAR? The cash exchanges are always less than $10,000.
What should the system for monitoring transactions of exempt persons consist of (when there is no automated system)? Is reviewing account statements annually ok and, if so, how many months of statements should be reviewed?
We have started using credit scoring for small business and some consumer loans. Reg B requires that we "validate" the scoring system (which is the credit reporting agency's FICO system). My question is "how do we validate this system".
Concerning Reg Z and the TIL form, when we find that our bank has improperly disclosed the APR and Finance charge on a mortgage loan, how do we go about calculating the reimbursement? Does this always automatically trigger a reimbursement? I have tried to find info on it in the regulation but have not found anything to help.
I need a quick summary of our obligations regarding interest recalculation and possible restitution if we discover that we are not paying interest on deposit accounts as disclosed in the Truth in Savings disclosure.