Are there any regulations that govern ATM card issuing for rep payee accounts (SSI/SSA)?
If we have a Middle initial...say "John Q. Doe"...this is how the client's name appears on the his DL. Do the OFAC regs REQUIRE that we the Bank demand to know what the middle initial stands for...in order to check John Quincy Doe with OFAC? If we do not check for the middle name, are we out of compliance? Please advise.
If a loan is more than 30 days delinquent, can we withdraw funds from their escrow account to make their payment? Are we also obligated to pay their property taxes if there are no escrow funds available to do so? Also, please let me know where I can find the answer in the regs. I've searched RESPA with no luck so I'd like to know how to be better at researching.
What is the timeframe for returning a check that our customer notifies us is a forgery? What are the regs that pertain to this?
A customer has a DBA sole proprietorship using his social security number. Are there any regs, etc., that say it cannot be in a "personal type" checking account? We only have a "commercial account" and nothing for the small "mom and pop" type of business.
We perform security training at least annually to our bankers. We have separate loan production offices where mortgages are made. They don't participate in the training because they have no tellers, no vault, no cash. Are we OK with this?
Our bank wants to put a loan application on our website. What disclosures are required?
Do we need to do anything to our OFAC policy in regard to the new international ACH transaction regulations? We already run all names through OFAC.
One of the operational units within our bank offers customers the opportunity to purchase gold and/or silver coins and have them delivered to their place of residence via the US Postal Service. In the case of US Mint coins , such as $50 Buffalo gold coins, are these considered "currency" for purposes of CTR filing, and if so, what amount should be indicated on the CTR; the face value of the coins (ie. 201 coins @ $50 = $10,050), or the intrinsic value of the coins (ie. 201 1 oz. gold coins @ $900 ea = $180,900)? Can you direct me to any regs that address this question?
Is it required for a BSA Officer to be certified and what is an independent BSA gatekeeper?