By John Munn, Director, Nebraska Department of Banking and Finance
We are having a debate on how the Phase II exemptions work. I thought when you exempted a phase II customer, they could only be exempt for deposits or payroll withdrawals. Another person here thinks if it is a Phase II customer, they are automatically exempt for deposit and withdrawals and that there is no distinction or specification about what types of transactions are exempt.
We were discussing putting a statement in our safe deposit box agreement that the customer agrees not to place currency, coin, jewelery or any other valuables in their safe deposit box. Are there any laws against this type of verbiage and is it effective in a lawsuit against the bank for missing items?
Currency Transaction Reports (CTR) and Suspicious Activity Reports (SAR): Reading With Context By Regina Stone16
Is the owner/operator of a privately owned ATM considered an MSB?
I thought a SAR was filed for amounts from $3,000 up to $10,000 and a CTR was filed for amounts over $10,000. In a situation involving more than $10,000 our bank is telling us we need an SAR and a CTR. Why do you need both if they serve the same purpose.
We have a customer that is a Phase I exemption, however, we just found out during our annual review that they have been purchased by another company that does not fall under Phase I. What steps do we need to take?
Are your Phase I exemptions permanently exempted or do you have to remove them once they don't have 8 qualifying transactions?
I know when a customer purchases a monetary instrument in amounts between $3,000 and $10,000 using currency that the customer first deposits into the customer's account, the transaction is still subject to the recordkeeping requirements. Is this only for transactions that take place on the same day?
SARs reporting suspected mortgage loan fraud continue to increase. This study includes SARs reporting suspected mortgage loan fraud filed between April 1, 2006 and March 31, 2007.