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?
When a parent opens an account for a minor and uses the minor's Social Security number, but only the parent signs on the account, is the ownership of the account joint or individual?
Question: Can we use the same form when we put a hold on a savings account deposit that we use on our checking accounts?
Can a legal hold be placed on a checking or money market account for loan collateral?
The OCC actually put out a notice that there really is no such Internet bank as the First National Bank of Bedrock - though there really is a Bedrock (population 10) in Colorado.
A Japanese bank is fighting back against a type of identity theft common to that country - theft of a person's deposit bank book - with a new biometric tool - one that uses the veins in a person's
Question: Is there a difference between CIP programs for loan customers and for deposit customers?
Under the revised Article 9, we are required to terminate the UCC on consumer goods when the debt is satisfied. What is the definition of consumer goods?