07/16/2017
Has the Fed’s new rule done anything about using mobile deposits to “double deposit” a check?
04/14/2014
Three checks - all the same amount and same serial number - were cashed by our customer and subsequently returned to our bank as unable to locate. The prosecuting attorney is asking for a definition of unable to locate and I am having difficulty locating this information. Please advise how I can respond - without this information the prosecuting attorney doesn't feel he can win the case.
07/08/2013
I have a customer who was a partial recipient of loan proceeds. He asked that his part be disbursed in several cashier's checks made payable to his son. The son then would come in and cash the checks separately. Some needed a CTR and some not. I'm trying to decide if this warrants the filing of a SAR on either the father, the son or both?
04/29/2013
Do you have to run OFAC on non-customers presenting VISA debit cards for payment of social security or tax refunds?
09/03/2012
We have a potential new customer who does business as a scrap dealer (appliances etc.). He receives checks made out to the name of his business. Does he need to have an account titled with the business name or can the checks be deposited into an account in his name, since it is a sole proprietorship and does not have a federal tax ID for the business? How should sole owner accounts be set up?
08/20/2012
The wife of the member withdraws $6,500 from their joint account. Later that day, the husband comes in with several checks. He wishes to just cash them, which amounted to about $4,500. In total the cash was $11,000. Do we need to file a CTR, and if so, do we do it on both?
08/06/2012
We have customers who have social security checks for dependents made in the following manner: "John Doe For Jane Doe" wherein in some cases the dependent is either a child or disabled person. I argue that these checks are payable to "John" as he is the first payee, and "Jane" is not actually a payee. Therefore, the check should be negotiable by John, or depositable into an account held solely by John. My FI has recently instituted a rule requiring these types of checks to be deposited into a) a UTMA account for "Jane" b) a Rep-Payee account for Jane or c) an account held solely by Jane. As in many cases Jane is either a minor or disabled, I believe forcing an account to be opened under her name to be irresponsible banking. I would like to know the guidelines for negotiating a check made either to "John Doe For Jane Doe" or "John Doe For the Benefit of Jane Doe"
07/23/2012
Can the successor trustee use their name and Social Security number for titling with the trust name listed secondary? I have a copy of the appointment of successor trustee for my customer. She receives checks payable to her as successor trustee for the trust. Do I need the customer to obtain a TIN for the trust?
05/21/2012
Our FI charged off a checking account and the person no longer has an account relationship with us. Another FI in town called inquiring about the status of the account. Apparently the person is writing checks off of the closed account and cashing them at the other FI. Who is responsible for filing a SAR? Would it be the other FI since that is where the transactions are occurring? Or since we now have knowledge of the activity are we required to file?
05/21/2012
Our FI charged off a checking account and the person no longer has an account relationship with us. Another FI in town called inquiring about the status of the account. Apparently the person is writing checks off of the closed account and cashing them at the other FI. Who is responsible for filing a SAR? Would it be the other FI since that is where the transactions are occurring? Or since we now have knowledge of the activity are we required to file?
