If we decide not to bank any marijuana related businesses, should we still have customers sign a non-engagement form, stating they won't conduct marijuana related activities? Will this protect us as a bank or harm us legally?
What criteria should be used to evaluate the capabilities of document management software?
Where does the FFIEC publish its reports?
Is there any regulation that requires the bank to have a PO box for mail delivery instead of delivery at the street address of the Bank?
We are looking to revise our daily disclosure notice to our Sweep account customers. Are there guidelines/samples available in some reference? I am having a difficult time finding the notice requirements.
Can a customer be charged an overdraft fee if the overdraft is a result of pending transactions?
When doing a Reg. CC review, holding funds for too long or too much constitutes a clear violation. What if, for example, the Notice of Hold was not completed properly (placed big "X" through all reasons as if to say N/A to all, or they simply selected no reasons, or left out the number of days funds would be held). I've received feedback advising these are not violations, just "exceptions/knowledge gaps" and on a review should be listed as such.
Business using RDC to deposit checks that it issues to and cashes for non-employee service providers. We bank a local recycling service. Historically, this customer has paid individuals who bring in scrap metal in cash. However, their regulators are now pressuring them to issue these individuals checks in lieu of cash payments. Our customer would like to issue these checks, immediately exchange them for cash and then deposit these checks via RDC. I understand that Fincen issued guidance (FIN 2006-G005) indicating that this activity is not considered MSB activity even in cases where the dollar amount is over $1,000, for one person and in one day. I would consider the overall risk of this activity to be low given that our customer is writing, cashing and depositing only their own checks and therefore disputes are unlikely and would only lead back to our customer. I am wondering if there are any requirements that the bank needs to enforce on our customer regarding this activity, such as CIP / ID requirements for the payees of these checks. I imagine that the individuals who are collecting scrap and turning it in for payment may be at a higher risk for ID problems, either lack thereof or forged / altered. Is this the banks concern?
I was wondering as a teller, legally, what am I allowed to say when a member asks how much they can withdraw without a CTR filed?
What are the rules for advertising on mobile devices, such as ads our mobile customers see on their smart phones?