If the same two owners of a CD want to swap the primary role, do we need a new signature card? Do we need written permission from both?
I exempted a customer last year after they met the Phase II requirements. Should I file on them this year until they meet the frequent transaction requirement of five transactions or are they exempt until they do not meet them for this year?
Could you please tell me of a source for BSA training for our Board of Directors?
I have a note that references a Security Agreement but there is no Security Agreement attached. Instead there is a UCC that is being use as a Security Agreement. Is this okay, or should there also be a Security Agreement that references the UCC?
We are looking to provide the Board of Directors with an annual report card on our BSA/AML program (with information such as how many CTRs; we filed how many SARs; and how many SARs were investigated and not filed etc.) Are there any templates out there for this type of report to give us a starting point?