In suspicious activity reporting, how long after the original SAR is filed should the bank track and try to connect to that ring before filing a new SAR. Updates or amendments to SAR's filed in the past seem to diminish the value of the information if we are updating reports from sometimes years in the past.
I have a HMDA question. I have loan that is to purchase an apartment complex, 60 apartments in 5 separate buildings. Do I report this all at once or do I report each building separately?
Can we pull a credit report on a customer without their consent? We have a customer who wants to consolidate some credit card debt. We told her that she needed a co-signer. She gave us her husband's social security number. Can we pull a credit report without his authorization?
Recently, our New Accounts has opened a few Guardianship Accounts. They have the proper documentation but we believe that the accounts may be under the incorrect social security number. What social security number should the account be filed under? Is it the Guardian (representative) or the Guardianship (beneficiary)?
As a community bank, we do not open accounts for MSBs due to the risk. However, we have several businesses that are agents of MSBs such as Sigue Corp, RIA Financial, Moneygram, and Western Union. Is the MSB responsible to see that these businesses are meeting reporting requirements, or are we to enhance our due diligence in overseeing these accounts?
Can a grantor on a trust change her social security number to a TIN without closing that account?
In Florida, when a minor's account is opened, is the account reported under the minor's social security number or the adult's? This is not a FUTMA account, only a minor's savings account.
Is a CTR required to ship excess cash to the Federal Reserve?
SARs must be filed within how many days of detecting a suspicious activity?
I am opening a guardianship account. Do I need IDs from the owner (ward) or just the guardians. I do have the court papers.