We are getting hit hard with fraudulent new accounts who deposit $50 to open the account, then deposit a bogus or NSF $9,000 check two days later and withdrawal that amount before the check is returned. Any ideas how to legally stop this from happening without offending legitimate new customers?
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.
Lucy Griffin explained to our Minnesota Bankers compliance group that we must not keep photo copies of picture IDs in loan files because of a possible Reg B violation. However, we also do this when we open new accounts (it could be helpful in cases of identity theft, or just so staff will recognize new customers). We also do it when we make a credit card cash advance for noncustomers, as we have experience identity theft there. Can we do this in nonloan situations and not run afoul of Reg B or other regs?