Most Popular Operations Content
CTR Required for Cashing Loan Proceeds Check?
12/15/2003
If a customer gets a loan for 15,000, and the bank gives him a cashier's check for the loan proceeds and he goes out into the lobby and wants the $15,000 cashier's check cashed, do I file a CTR for this?
Keeping Customers After a Merger
12/15/2003
We are a small community bank that is being bought by another community bank whose headquarters is about a half hour from our offices. Our name will mostly stay the same for a couple of years and we will still hold our presence in our community. I've heard people talking out in the community about leaving as soon as the merge starts - so I'd like some advice on what we should do to try to keep as many customers with us as possible.
Noncustomer Purchase of Official Check
12/15/2003
Can a noncustomer purchase a bank check or cashier's check? If so, how are SARs or CTRs filed without all their personal information known. I can see this as a loophole to try and launder money.
Sharing Information for Joint marketing
12/15/2003
Our bank shares nonpublic personal information with an unaffiliated third party with whom we have a joint marketing arrangement for marketing credit card accounts. Under the agreement we are required to provide them in an electronic format the names, addresses, telephone numbers and social security numbers of our existing customers for the purpose of allowing them to solicit our customer for credit card accounts. Are we allowed to disclose telephone numbers and particularly social security numbers without providing our customers the opportunity to opt out? Our initial and annual disclosures do contain the required verbiage that we may disclose all of the information we collect to companies that perform marketing services on our behalf or with whom we have joint marketing agreements?
Tax Levy Goof?
12/15/2003
The bank received a IRS tax levy and researched the TIN's name, business name, and address provided in the levy, and found no records based on that information. After being contacted by IRS stating that they were sure that the individual named in the levy had an account with us, I ran a broader check and found the name of this person listed as a secondary owner on a joint account. I asked the IRS if they could provide additional information in order to accurately identify this person. Should I have immediately placed a hold on these funds, or was I correct in asking for more identifying information before freezing the account?