Regarding BSA, what are the bank options if a non-customer wants to cash a large on us cashier’s check, but refuses to provide a social security number?
Can you offer a best practice answer to customers who ask about CTR reporting requirements? Example: How much can I deposit or withdraw without it being reported?
We receive weekly deposits from three merchants, two of whom have exempt status. The individual making the deposits for these two customers also makes an additional deposit for a non-exempt customer. The dollar amount for the non-exempt is usually between $1,000 and $2,000 in cash. The question: Should a CTR be filed for the total three deposits, even though two of the customers are exempt, since one individual brings in the total deposits (exceeding $10,000 in cash) in one bag? The same applies for night depository; they place all three deposits on one bag.
How can the bank optimize its vendor risk management efforts?
We have several attorneys who maintain IOLTA accounts with our bank. They all use the same tax ID and their transactions aggregate on the large cash transaction report. If they are acting independently, would we still need to aggregate the transactions for CTR reporting?
An individual is the trustee of his revocable living trust and signs the security document both as the individual and as the trustee. For HMDA LAR reporting purposes can we report this loan as an applicant only type of loan because only the individual's income, credit and assets were utilized to underwrite approve the loan?
Identity theft occurs in many forms and can include additional crimes of false statement, computer intrusion, credit or debit card fraud, mortgage loan fraud, or wire transfer fraud.
By FinCEN Office of Regulatory Analysis
By Staff of the Securities and Exchange Commission6
How can I communicate compliance risk in terms that the business can understand and use to make immediate, measurable cost versus benefit risk decisions?