Relative to BSA/AML, is there anything within FFIEC guidelines, or anything else for that matter, that states a bank must get the purpose for a wire/funds transfer? At a previous institution that I worked at we were cited by the OTS because we were not obtaining the purpose for a wire transfer. I have spoken to other colleagues and they, too have been cited; however, no one can find where this is an actual BSA requirement.
When Reg E speaks of POS transactions, does that cover all debit card transactions, PIN used and PIN not used?
For Mobile Home Purchases, do we report the address of the Mobile Home or the Collateral address for HMDA?
We have customers with a joint checking account and they are also signers on a business account. One day, Mrs. Customer deposits $4000 cash in the joint account. On the same day, Mr. Customer deposits $7000 cash in the business account. CTR required?
Is it necessary to file a SAR on a customer for whose records we have received a grand jury subpoena?