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?
If a customer had someone make counterfeit checks with his account number on them and then that unauthorized person used these checks to purchase items from a store that processed the check electronically, what are the time frames for customer reporting and the bank returning the item as well as required paperwork? It appears we are crossing from checks to Reg E and I am not sure what applies where.
What regulations should be considered as we write our Remote Capture policy (Check 21, Reg E, Reg CC, etc.)?
- Approximately 12 million CTRs are filed annually. FDIC, Supervisory Insights, June, 2004
Do we need to scan our ACH Origination files for matches to the OFAC list? If so where does it state so.
- Customers who use online banking show 80% lower attrition from the bank, make 30% fewer calls to the customer service line, and have higher overall account and loan balances.
I need to know where to find the requirements on returning an ACH item over $2500. If it were a check, of course you contact the bank it is being returned to within the appropriate time frame under Reg CC. But, with ACH, I cannot find any guidelines.
The banking industry last year apparently negotiated $31 million worth of checks for people no longer alive.
Treasury announced that by August of this year 70% of benefit recipients received payments electronically, up from 50% two years ago.
According to the National Automated Clearing House Association (NACHA), financial institutions report as high as a 50% increase in daily check volume when a "lost Friday" occurs.