Is it a requirement of the Bank Protection Act to annually receive board approval for the Reporting of Criminal Acts Policy?
I recently learned that the bank filed a CTR on a customer who had been exempted from reporting. The CTR was filed almost a year ago, and since that time there have been many transactions that were not reported because of the exempt status. Would proper handling include filing late CTRs for all eligible transactions since the CTR that was submitted in error, and then resubmitting an exemption form to reinstate the status as exempt?
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?
What/where does one report insider banking fraud that includes the vice president, producing fraudulent checks with wrong routing numbers, and handing out wrong direct deposit forms?
I have been in banking for awhile and am being told I am making a mountain out of a mole hill. When it comes to DBA accounts, I have one opinion on what purpose/style account should be opened and I am being told by others that I am not correct. There are two differing opinions when we open a DBA account. For example, one opinion is that Mickey Mouse DBA Great Escape Mousetraps should be opened as a personal style account, where at the account maintenance level, the code would indicate consumer for the purpose of household or personal use. The other opinion is one in which it should opened as a business style account, where at the account maintenance level, the code would indicate business for the purpose of business. The reporting tax ID number in both situations would be the customer’s Social Security Number. If I understand correctly, there are different regulations regarding the purpose/style of an account and there are different protections and benefits for each purpose/style. Can you please help as to which purpose/style would be proper? My best interest is doing things the correct way for the both the bank and the customer.
Upon verifying the SSN of a new customer's information, it was found to be that of a deceased person. Do we need to fill out a SAR on this?
Recently in dealing with a non-resident alien, an ITIN was presented at the time of account opening. After researching on the irs.gov website and calling the IRS, I was told that an ITIN can only be used to file a US tax return. It is not to be used for any other purpose, including opening a bank account. In your question and answer page about non-resident aliens it mentions and ITIN can be used . Please clarify.
Do you have a security check list for what a bank security officer should be checking in the branches?
Other than a signature card, are we required to get any other legal documents when opening a representative payee account for an adult?
A lender approved a mortgage loan and did not gross up the customer's social security income, so for HMDA reporting, I used what the loan officer came up with in determining his income. Now, upon reviewing my quarter-end HMDA reporting, the HMDA compliance officer claims the social security income needs to be grossed-up and that I should change my HMDA LAR to reflect this change. Is this correct? I thought that I was to report my HMDA according to the data used to approve the loan application. Please clarify this for me.