If there are outstanding miscellaneous fees due (attorney fees, etc.) can we take the funds out of a customer's escrow account?
We are nervous about the method we are currently using to authenticate our online customers. We require the customer to put in their user name and a four letter password. Do you think this is sufficient?
I know that Reg P was subsumed into Reg H, and Reg P is now the privacy reg, but where are the specifics? Such as Minimum Security Devices? I know we still maintain the same standards, but it's hard to locate and show someone in writing...
Somewhere in the past I remember learning that a 1099 should be filed whenever an institution suffers a loss to an individual you can identify. Charged off loan, criminal asset loss as examples. Where can I find this in writing? I know the SAR requirements, I just need the IRS 1099information.