If a financial institution has evidence a customer is kiting, is it a violation of Reg P (or anything else) if that financial institution discusses information on the account to another financial institution? The only reason for these discussions would be to prevent both institutions from loss. It would also stop a criminal from further fraudulent activity.
Two questions regarding kiting.1) We have an account for an individual who writes a check from bank A (us) to her daughter. This item is deposited into Bank B. Then daughter writes check from Bank B (same amount) for our customer to deposit into Bank A (us, again) either same day or next. Does this fall under 'kiting'? 2) Also, we have a mother who monthly writes out 4 checks to her children (1 per child) and then re-deposits into the same account the checks are written from. Is this an issue? We aren't sure that the children are endorsing the checks sometimes they are endorsed For Deposit Only. Please advise on both of these issues.
Can you provide some guidance regarding CTR Exempt Account Reviews? What is the time period expected to be covered for the annual and biennial review (i.e. 6, 9, 12 months) for suspicious activity and what supporting documentation is expected to be in the file (i.e., copies of monthly statements, deposit detail -cash in, checks, checks reviewed to determine if unusual for the business)?
As per section 103.18 of the Bank Secrecy Act, "A bank is required to file a SAR no later than 30 calendar days after the date of initial detection by the bank of facts that may constitute a basis for filing a SAR." The question is, when is the initial detection required to occur? For example, if it takes say 14 days for the detection of the suspicious activity, does the bank have 30 days from that date to file the SAR?
What are the compliant steps to prove a suspicious account for check kiting?
Can you give me a description of a cash kite (also known as grocery store kite)? What are the risks to a bank with this type of activity? Would this activity call for a SAR being reported?
Do you have anything available that would give examples of "Recognizing Suspicious Activities" for filing a SAR? e.g. kiting, fraud, e.g. a teller ......, a customer......
We have a procedure to review unusual activity in employee's accounts on a regular basis. In addition, if we have a suspicion regarding a teller, we have reviewed account activity for that teller. Are there any privacy rules which would restrict our ability to review our employee's account information? Also, is there any consent required by the employee when they begin employment?
Real Estate Industry ? Sales and Management SARS
We have a credit card account with a balance of $3,000. The customer sends in a payment for $3,000 which is NSF. The customer charges on the account before the payment is returned and has a $6,000 balance when the NSF payment is returned. Is this a SAR reportable incident? Does the $3,000 NSF payment determine the dollar threshold for reporting or does the $6,000 account balance determine the threshold for reporting?