03/16/2009
A big part of our IT Security budget is spent on GLBA compliance. Are we doing something wrong?
12/15/2008
When issuing a corporate check is there any clear ruling as to who is authorized to sign? Bylaws state that the CFO can sign. Can this be delegated to other employees?
12/15/2008
What is the best way to get buy-in from key players that need to be involved in the risk assessment process? How do we sell it?
12/08/2008
Are bank employees, other than executive officers, allowed to have overdraft protection on their checking accounts under Reg O?
12/01/2008
I know that in the FHA it says that it is not necessary to put the bank's name in an OREO advertisement. When putting the contact information shouldn’t you put down the bank's number? One of our directors put an advertisement in the local paper and at the bottom it reads "for more information contact..." and then it has his name and phone number. I can’t find anything in the Reg about this.
11/24/2008
Our regulators have requested that our bank more clearly define and document its credit policies. What should be included?
09/22/2008
What position (head teller, loan officer, etc.) of the bank would be the best candidate for our BSA officer? Would it be our compliance officer?
03/31/2008
I plan to include a recommendation in my annual report to change the current reporting structure for the Security Officer. Presently, I report to the VP of Retail Operations. I am seeking references to cite that advise the bank security reporting structure should be in other areas such a finance, risk, administration, but not through retail because of the apparent potential for downward influences and the need for independence.
12/10/2007
How in-depth should the training be for the Board of Directors in BSA? Is a general overview of BSA/AML/CIP along with an overview of the procedures in place sufficient for compliance?
02/26/2007
What is the official rule regarding cash back on deposits for business accounts? (Sole proprietorships, corporations and general partnerships.)