06/21/2020
When is the 2020 FFIEC BSA Exam manual effective?
06/14/2020
Do we have to change our Savings Deposits?
06/07/2020
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
05/31/2020
Is a US TIN enough for a NRA on an interest bearing account?
05/31/2020
My bank’s account disclosures indicate it has a general next-day availability policy, but also says that we can place exception holds. Does that mean we can also place case-by-case holds?
05/24/2020
Can my customer waive and RMD for an IRA?
05/24/2020
What’s the combination of large deposit and case-by-case holds we can use to delay availability as long as possible of as much of a mixed-check deposit that includes next-day checks and other checks as possible? We want to delay the customer’s use of as much of the deposit as possible for as long as possible, within the “safe harbor” holds limits. The deposit is made in person to a bank employee to an account held by a payee of all the checks.
06/09/2019
Per Reg CC, a banking day is defined as any business day (up to the bank's cut-off hours) when your institution is open for substantially all of its banking activities. Reg CC measures availability of funds in business days.
Are we, the bank, allowed any time from open of business to 3:00 pm (our cut off time) to release a hold? Our disclosure goes over the terms Business Day and Banking Day. But under the delay we use Business Day. So should the funds be available the start of business day the hold is removed?
06/09/2019
I'm implementing Remote Deposit Services in my bank. Our main and only customer will be a foreign bank. Basically, the foreign bank is my parent company. However, we are independent from them in terms of regulations applicability.
The foreign bank is not allowed to open US dollar accounts for their customers. Therefore, the foreign bank will purchase checks from their customers and each will be scanned through RDC. We will receive the images of the checks.
My question is: Does regulation CC apply to the foreign bank (which is my customer)?
05/19/2019
I'm hoping you can confirm my understanding that a paying institution is liable under Reg CC 229.38(a) for failing provide notice of nonpayment for a check in the amount of $5,000 or more under 229.13(c)? The measure of damages under 229.38 is the loss incurred up to the amount of the check, less the amount of the loss that would have been incurred had the paying institution exercised ordinary care. Can you provide an example of a liability calculation in which the paying institution's notice of nonpayment is late?
How does the bank of first deposit pursue a claim against the paying institution for failing to provide proper notice by the deadline? I assume this would be on a "without entry" basis by sending a demand letter to the paying institution.