Is the "Official Interpretations" section of Reg E subpart B Remittance Transfers part of the Reg or just someones interpretation? Section 1005.33(a)-5. i., ii., and iii. Procedures for Resolving Errors. This makes no sense to me to hold the sending bank accountable for something beyond their control. I would think an error such as this would fall under "Extraordinary Circumstances." I have to present this to our President and CFO so your answer on this would be greatly appreciated.
Relative to BSA/AML, is there anything within FFIEC guidelines, or anything else for that matter, that states a bank must get the purpose for a wire/funds transfer? At a previous institution that I worked at we were cited by the OTS because we were not obtaining the purpose for a wire transfer. I have spoken to other colleagues and they, too have been cited; however, no one can find where this is an actual BSA requirement.
I know there have been lawsuits against banks due to fraud involving unauthorized ACH debits on business accounts. What is the status of those suits?
Is the Bank required to have a special procedure section on the DATA form? Should we give the client the option to decline the use of the security procedures that are offered by the bank?
We have a customer who filed several Reg E claims. During our investigation we referred the claim to our Security Director who wanted to meet with the customer to discuss the possible identification of a party caught on video. The customer has not returned numerous phone calls and e-mails. Can we refuse the claim for lack of cooperation on the customer's part?
Regarding automated telephone banking systems, customers can currently inquire (get account balance and info) by phone with their account number and last four digits of their SSN. If they want to transfer funds between their accounts, they must complete an application. My bank wants to give automatic access to transfers too. I'm concerned about Reg E issuing access device rules. Is calling the number and following the steps, "requesting" the access? We have new operations personnel who say all banks do this automatically. Other banks don't have customers fill out a form or call and talk to someone, it is all done through the automated phone system. Does this comply?
What are some things we can recommend to our business customers using online banking to protect them from losses such as those we read about in the tech papers?
What are the error resolution and disclosure requirements for pre-paid gift cards? Is the financial institution required to notify its customer base of the gift cards prior to them being offered for sale?
If a bank acquires loans through an acquisition, are new CIPs required? What would be involved from a BSA standpoint?
By FinCEN Office of Regulatory Analysis