If a financial institution discovers a crime or fraud and wants to notify law enforcement, what if anything is needed before records/documents are turned over to help with the investigation?
When a customer notifies us of a potential fraudulent activities on their account, we place the account on a "restricted" status (any debits trying to hit will reject and have to be worked manually) for a maximum of 90 days. Is it safe to remove the restricted status if no fraudulent activities occur? What would be the best way to handle day 91?
DDA customer account auto closes because the balance went to zero. Customer comes in 2 days later wondering what has happened. Must they be re-CIPed to re-open their account?
Does the bank require Letters Testamentary dated within 60 days to cash in a CD belonging to the deceased? Is there a central database containing CD information? Can we search accounts by his social security #?
We have three restaurants that are owned by the same individual, and each of the businesses has a cash deposit just about every day. Our operations manager wants our tellers to combine the cash deposits of the three companies for CTR filing, because the same individual benefits from deposits to all three accounts. Is that correct?
We received a levy, and the customer has a CD that is pledged as security on a loan. Does our perfected security interest trump the levy or do we have to exercise our right of offset (cash the CD and pay the loan) in order to not be required to satisfy the levy with it? Secondly, if a customer we get a levy on has both deposit accounts and loans, do we have to exercise our right of offset or does simply that right trump the levy. Can the bank say there are no funds available to satisfy the levy, even if the right of offset is not actually invoked, assuming the customer owes more in loans than is in the deposit account?
What information is needed to open a business account?
I have a very technical GLBA question. It is my understanding that if all employees of the bank are required to have deposit accounts then they are also considered a customer under GLBA. If there happened to be a breach of employee nonpublic information through the HR department, say the payroll vendor was compromised and all employees' social security numbers were released, would this not be considered a breach under GLBA and notification required to the affected customers (employees) along with notice to our regulators? Is it possible since the breach occurred through HR department and was of employees' nonpublic information that it is not defined as a breach under GLBA?
We have a customer that has a home equity line of credit. They run a check cashing business with it by bringing in the checks and applying them as a payment, then doing a large advance from the loan to take back to the store to use in cashing checks. I regularly file CTRs on them, but do I still need to treat them as a MSB even though they do not have a business deposit account? Do I need to have them fill out questionnaires just like I would do on a deposit account?
In reviewing an auto loan app today I noticed the customer has had 13 auto loans in the last 24 months (June '04 to June '06). He trades them in, usually with the same dealer. He has never made more than 2 payments on a loan. He first became our customer in July '02 and through Aug '03 received 9 separate auto loans, with this same pattern - one or two payments and trades off. Three off the loans in his whole portfolio received large principal reductions as one of their payments. None appear to be in cash. Is there cause here for a SAR? Or is this simply an aggravating customer?