If an IRS Special Agent purchases a cashier's check payable to the Department of Treasury with more than $10,000 in cash, is a CTR required?
We normally take a copy of the driver's license of a new commercial borrower and put in the file for CIP purposes. We are now being told that we need to complete a CIP verification checklist and have that in the file also. Is the checklist necessary and if so, can you direct me to the regulation?
Question: We know that there is overlap between Red Flags and BSA/AML but what are the common functions?
If we adopt the overall bank policy that we will no longer sell monetary instruments to non-customers, and in addition require our customers to deposit cash into their accounts and then debit their accounts for official check purchases, will we still have to keep the Monetary Instrument Sales Form and Log? Can we adopt this policy and pass our examinations?
At our bank we have to do screen prints of when we do OFAC checks. How long do you advise that we hold these copies for?
Question: We have been photocopying bait money for record keeping purposes for many years at my old small bank.
BSA regulations (31 CFR 103.33(a)) require records to be maintained of all extensions of credit over $10,000 not secured by real property. One of the items that must be retained is the loan purpose. How specific must the purpose be? For instance, is it adequate to record the loans as: passbook loan, business line of credit, etc.?
Is the bank required to have 2 forms of identification to open an account? Our Compliance Officer says it is the legal requirement of the Patriot Act, however I cannot find where it is required, only recommended.
One of the FACT Act's new requirements is that creditors dispose of information obtained in a credit report in a timely fashion.
by Barbara E. Hurst, Editor
It's the beginning of a brand new year and I'm going to take time out to pat a few of you on the back.
Here's a toast to: