What is the best type of review or audit performed on employee accounts? What are the recommended intervals and best way to show the findings or results?
When an account holder has more than one account and the first account review reveals that there are no protected funds and there is sufficient funds to satisfy the judgement, are we required to conduct a review on any remaining accounts? When reading section 212.5 Account Review, I am finding that we should perform an account review on all accounts. (f) Separate account reviews. The financial institution shall perform the account review separately for each account in the name of an account holder against whom a garnishment order has been issued. In performing account reviews for multiple accounts in the name of one account holder, a financial institution shall not trace the movement of funds between accounts by attempting to associate funds from a benefit payment deposited into one account with amounts subsequently transferred to another account. However, I am finding in the analysis of the final rule that agencies agree that it serves no useful purpose to follow the rule’s procedures in situations where a financial institution has made a determination not to take any action affecting an account as the result of the receipt of a garnishment order. The analysis also goes on to say that that if a financial institution will not be freezing or removing funds from an account in response to a garnishment order, then the financial institution should not perform an account review to determine if a protected amount should be established. Does this mean that we don’t have to do an account review on the remaining accounts if there are no protected funds and the amount satisfies the judgement in the first account? In our situation, the first account review did not have protected funds and the amount satisfied the judgement, but some of the remaining accounts do have protected funds. If we do have to review all accounts, even if the first review satisfies the judgement, are we still required to send the notice since other accounts did have protected funds, even though no funds were garnished from those accounts?
On a joint account, Bob or Betty, if Bob makes a deposit and Betty makes a deposit, do we really have to do four part Is
When will banks and credit unions be able to use estimated exchange rates after July 21, 2020?
Our customers who want e-disclosures click on an “Enroll Me” link. Is that good enough for compliance?