Filings on Mortgage Brokers
What are the risk of setting up a Qualified Income Trust account for the financial institution?
Can you provide a list of required officer positions? Are these requirements listed in the regulations or are they simply suggestions? I'm trying to determine which officer positions are mandatory for compliance so I may pass this information on to Executive Management.
Should a mutual savings bank have a "Safety Committee” or is it sufficient to have a Security Policy and a Security Officer?
Are funds held as collateral exempt from an IRS levy, or do these funds need to be included in the bank's response to the IRS levy received?
Is there a requirement to run an OFAC check on a DBA? For example, John Doe DBA ABC Store. Do I need to run an OFAC on John Doe and ABC Store, or simply John Doe?
We are regulated by the FDIC. Are we required to OFAC screen any local organizations prior to making any charitable donations to them?
I'm trying to figure out if CIP is required on the merchants for whom we process ACH transactions. Here's the scenario. Company A (Merchants) sells goods/services on the internet. They send their debit and credit transactions to Company B (Payment Processor), who then in turn sends their ACH files to us for processing through their account(the merchants does not have an account with us). We perform all BSA requirements for the processor because they are our customer, but I am wondering if the merchant is considered our customer as well, or just a customer of the Payment Processor? Should we be obtaining CIP information on the merchants?
I want to add something to my annual security training directed to management and the board. Do you have any suggestions?
How long should security surveillance recordings be kept? Are there any recommendations as to how long recordings from the safe deposit vault and that area should be kept?