What can we put down as the reason for denial on the Adverse Action Notice, for loans denied due to criminal subpoenas? Can we select "Other" and specify "BSA concerns"?
Do we need a policy on providing payment extensions to borrowers?
Customers see on the news that foreclosures and evictions have stopped and borrowers can skip payments. What should we tell them when they ask about this?
I started in BSA a few years ago and I built an Enhance Due Diligence program for higher risk customers with monthly transaction review and then yearly comprehensive review of the business and its expected vs actual activity. At the time I found a really clear outline of expectations in the BSA Manual and now I can't find anything related to EDD at a all. Did this get removed? Anyone else experiencing this?
If a SAR is submitted on the due date using an automated system is it considered to be on time or does it have to be accepted by FinCEN by the due date.
At what point in the process do we start conducting due diligence on loans and does it differ between loan and deposit accounts?
Does the Interagency Exam Manual for BSA include any training requirement for lenders?
May a lender delay the processing of a home loan application because an applicant is on maternity/paternity leave?
What does it mean to ensure my vendor is financially stable?
A person opens a DDA, is properly CIPd, and his name includes "Jr." as a suffix. Later, the same person, same SSN, borrows money without using the "Jr." suffix. Should the lender require the borrower to re-sign the promissory note using Jr. in the borrower's name?