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Vendor Guru Q&A - Operations

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Latest Operations - CIP Topics

IRS Levy for Individual-No Personal Account

11/04/2018

We received an IRS levy for an individual. We have no personal account, but there is an account where the individual is the sole owner on a business account and incorporated. Does the levy effect this account? And do the new Beneficial Ownership regulations impact this at all? This individual is really using this as a personal account and even deposits Social Security checks into it.

Transferring of Accounts (Beneficiary & IRA)

07/15/2018

The majority of our IRA customers have their spouse listed as beneficiary. When an IRA holder passed away, we would change the title to the "Spouse as Beneficiary of the deceased IRA" and their SS# if they chose to not treat as their own. We had two IRA holders (in RMD) pass away this year and had multiple children listed as beneficiary. We set up separate accounts for each child as "Beneficiary of the fathers IRA" and transferred the funds to them. This was done "in-house" with transcodes to just transfer the funds to the separate accounts (no paper work other than the entries). What is the proper way to handle the transferring of accounts like this? Should we have completed new account paperwork for a new IRA account? For CIP purpose?

Concealed Handgun License as Primary Proof of ID

07/15/2018

Based on the change to Texas law Sec. 506.001. CONCEALED HANDGUN LICENSE​ AS​ ​VALID PROOF OF​ IDENTIFICATION. (a) A person may not deny the holder of a concealed handgun​ license issued under Subchapter H, Chapter 4l l, Government Code, access to​ goods,​ services, or facilities, except as provided by Section 52l.460,Transportation Code, or​ in regard to the operation of a motor vehicle, because the holder has, or​ presents, a​ concealed handgun license rather than a driver's license or other acceptable​ form of​ personal identification. Does this mean that community banks must accept the ​concealed handgun license as a primary form of​ identification? Or can we use it as secondary to other identification and​ still be within the law?

Reason for Decline on Notice of Action Letter

07/15/2018

If an applicant for an account passes all the BSA and CIP qualifications (ID verification, chexsystems, credit report) to open an account, yet the bank employee has an uneasy feeling or is suspicious of their intentions, are we able to decline the applicant for the account? If not, what options do we have to protect the institution from a loss? If so, what should we provide as the reason for the decline on the notice of action letter?

BSA/CIP Control Prong Requirements

07/08/2018

I have a branch that is telling me that a business that is opening an account is syndicated and set-up for tax credit reasons. This is a rather large country-wide real estate developer and I have no information that excludes this type of entity from either the beneficial ownership or control prong requirements. They appear, to me, as just a for profit business as any other. Am I correct in thinking that both prongs apply and no exemptions apply.

Automatically Renewable CDs-Beneficial Ownership

06/03/2018

As I understand the new beneficial ownership rules, certificate of deposit rollovers and loan renewals are treated as new accounts and require beneficial ownership information to be obtained at renewal of the account. Renewed loans are easily taken care of but automatically renewable CDs are not. Unless the CD holder does something new, they do not normally come back to the bank. What is your best advice as to handling automatically renewable CDs and the requirements of beneficial ownership? We are planning to contact these customers prior to the maturity date asking them to come into the bank but this doesn't mean that they will.

BSA Beneficial Ownership Requirements

04/08/2018

Do the beneficial ownership requirements apply to an account that the bank acquires, and does it make a difference if the bank acquires it from another institution that is required to follow beneficial ownership rules or from a broker who may not be required to comply?

Military ID Sufficient for Opening Account?

04/01/2018

Is use of a military ID sufficient for opening an account or doing a name change on an account? I'm looking for where Military ID's are not suppose to be used for identification, and having a hard time finding the regulations behind that or maybe I completely misunderstood and am wrongly assuming that we are not able to?

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Most Popular Operations Content

E-SIGN Requirement for Accessing Acct Statements

11/11/2018

We have had an internet banking platform for several years and are preparing to roll out the mobile banking interface to internet banking customers. Through both the online platform and the mobile platform, customers are able to access account statements. We currently also provide paper statements to all customers, including those who are enrolled in internet banking. Customers are not able to choose between paper statements and electronic statements in the internet banking platforms (i.e. internet banking customers with access to electronic statements also receive a paper statement). Are we required to be compliant with E-SIGN due to the internet banking customers being able to access account statements electronically, even though they are receiving paper statements?

Non Resident Alien Sign on Safe Deposit Lease?

11/11/2018

Questions have been brought up...at our Bank, a Non Resident alien can open a deposit account, but can they also sign on a Safe Deposit Lease? What happens when the party is deceased? Is this a Bank preference to rent or not? ken

Bank's Responsibility-Diminished Capacity Customer

11/11/2018

What is the bank's responsibility in regards to customers with diminished capacity? I have an elderly customer with dementia who makes frequent trips to the bank (often multiple times a day) and is in an advanced state of confusion. He often requests to take all of the money from his sizable checking account. While he has every right to his money, we are concerned that he is incapable of managing his finances on his own and is an easy target for criminals. He is walking around with a significant amount of cash in his wallet. While it does not appear that he has been abused financially, he does not have family who is willing to help him out. It is obvious that he no longer needs to be in control of his finances. As his bank, what are our options as far as keeping both the customer and his assets safe?

National Gun Trust-Open Acct. Under SSN?

11/11/2018

We had a Gun Trust presented to us to open a Trust account for. We declined the account. Can an account be opened for a potential client for a National Gun Trust under his SSN?

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