I am in the process of revising our teller procedures to include checking all non-customer transactions against the most current OFAC list. I am still not clear on the non-customer transactions that should be checked. Could you clarify that for me and also, cash and checks both? My understanding is that tellers need to check on the following: all negotiable instruments sold (cashiers checks, money orders, wires, bonds, travelers checks). What about non-customer cashing an on-us check?
I've been talking with some co-workers in the Loss Prevention community regarding the use of a consumer report. I've been told by some people that it can be a very useful tool if you're trying to track down someone who owes your company money. They've also said that it's OK to use a consumer report without a customer's consent if the report is being used exclusively for customer who owes your institution a debt. Others have told me that under no circumstances should a consumer report be pulled without prior concent from the customer. What is the right answer? Are there good alternatives to using a consumer report?
I was wondering how other banks handle criminal background checks for interns. For new hires, we fingerprint them and submit them through the ABA / FBI program, but by the time I get the clearance back, the interns are usually gone. Any opinions or advise would be greatly appreciated.
When a branch office checks their DVR system prior to opening and finds it not recording, should the branch operate under emergency opening procotcol until the DVR system is repaired? Our emergency opening protocol is to lock the branch, only letting a maximum of two clients in at a time.
What is the best way to handle members' accounts with claims of lost VCC/PINs, with "mysterious" deposits and withdrawals. The checks are made payable to the customer with the account numbers on the back, but the customer claims to know nothing about it.
What is your opinion on the risks associated with allowing consumers (individuals or non-businesses) to use remote deposit capture services?
Is accidentally exposing the incorrect check images to customers via online banking considered a reportable event for information security and privacy purposes? I am thinking that it is, since users can save the images to their desktop or other device. The check images are not images of the online banking user's checks, but of other customers' checks that contain bank account number, name, address and a signature.
I have three checks cashed from three different people, all on the same banking day. Added together they are over $10,000.00. Do I put their information in Part 1 of Section A or Section B? Since one of the checks was for $600.00, I didn't get a SSN; do I leave it blank?
Today, 10/6/10, we received multiple checks returned to our bank. They were all from one account at the paying bank, dated June through September. They were returned as forged signatures. I believe the liability falls on the paying bank, as these were not returned by the midnight deadline. What is the proper way to send these back to the paying bank? Do we do a check adjustment and state untimely return?
When issuing cashier's checks, does the party the check is being issued to have to be checked against OFAC?