09/20/2004
If a person comes into the bank and wants to take out a loan, but we deny the loan because the social security number has not been issued or the number belongs to a deceased person, are we required to file a SAR? Technically the person is not a customer and no money has switched hands. Also, if we have an existing customer with deposit accounts who wants to take out a loan, and at that time we discover the same scenario with their social security number, should we file a SAR and close their accounts?
12/01/2003
We open renters' security deposit trust accounts. Do we need to verify the tenant's ID and check his/her name against the OFAC list? I know that for the landlord we have to do this. Is it sufficient to just keep the W-9 on the tenant?
06/30/2003
I am reviewing the final reg for the CIP and making adjustments to the program and procedure we compiled several months ago. At the end of the discussion of Section 103.121(b)(2)(iii) for Lack of Verification, the final reg indicates "...a bank must comply with other applicable laws and regulations, such as the adverse action provisions under ECOA and FCRA, when determining not to open an account because it cannot establish a reasonable belief that it knows the true identity of the customer." ECOA and FCRA deal with credit products, and I do not see how the current notices apply to denial because you cannot establish someone's identity. Even if you mark "Other" the notice portion refers to credit and I believe it would confuse the applicant. Any thoughts on this?
03/03/2003
We are currently reviewing our employee accounts by looking at their bank statements and all of their checks and deposit slips. Is this acceptable?
03/01/2003
Question: I know Regulation CC - Expedited Funds Availability - has been around for a long time, but we're still having some problems with it.
02/01/2003
Question: It seems as if we will never get all the questions answered on the completion of CTRs. Ours is the completion of a CTR on deposits to joint ownership deposit accounts.
02/01/2003
Real-time online check verification and conversion took a large step forward recently when SafeCHECK Company LLC partnered with LML Payment Systems Inc.
12/01/2002
The American Bankers Association and the American Bar Association recently held their 14th annual Money Laundering Enforcement Seminar.
10/21/2002
Can an employee's deposit accounts be locked out if they have admitted to embezzling bank funds?
04/01/2002
by Mary Beth Guard, Esq.
LEVY OR ATTACHMENT? You Can Take This, But DON'T TOUCH THAT!