The new Beneficial Ownership rule adds the CDD Fifth Pillar to the AML program requirements for (a) developing a customer risk profile, (b) conducting ongoing monitoring for reporting suspicious transactions and, (c) updating customer information. What CIP procedures should we follow when a business client provides online banking access for an employee who has the authority to initiate transfers or make bill payments?
We are considering taking loan applications online. What are some key things that need to be considered as we go through this process? What questions should be asked?
We qualify loan applicants based on gross income. Our credit officer says that tax free income from SSI or VA Disability is the gross income and shouldn't be grossed up. I say the income is net and should be. Who's right? If we don't gross tax SSI up, are we discriminating?
Is there a certain sequence for state tax ID numbers? Do they start with a certain number per state/county?
Our bank wants to put a loan application on our website. What disclosures are required?
When reviewing our website, what are the main compliance issues we need to look for?
What is different about Daylight Saving Time this year and how will it affect my bank's systems?
Many financial institutions that offer health savings accounts (HSA) simply request that the HSA application with initial deposit, and only a copy of an ID as verification be mailed, not presented in-person. With numerous HSA's being established out of state, no in-person verification is requested and seems to conflict with the PATRIOT ACT’s customer profile information requirement. How can our bank open HSA’s and not have the customer do this in-person, can this be done strictly via mail?
Is a CIP notice required to be in place at each workstation where deposits might be accepted, for example, at an officer's desk or other location other than the teller line?
by: Scott Daugherty, Assistant General Counsel, Texas Bankers Association