I assume that on the loan side we need to determine whether the customer is an MSB and get all the required documents. However, from a practical standpoint, how does one monitor such a relationship if all they have with us is a loan?
Do we need to complete an OFAC check on the payee of every monetary instrument that we sell?
We are looking to implement email notification of receipt of deposit instead of mailing paper back. I have seen comments on e-statements and E-sign and disclosure requirements but don't think any of that applies to receipts. Can you refer me to the regulation that states we are required to provide a receipt and the corresponding rules?
As per section 103.18 of the Bank Secrecy Act, "A bank is required to file a SAR no later than 30 calendar days after the date of initial detection by the bank of facts that may constitute a basis for filing a SAR." The question is, when is the initial detection required to occur? For example, if it takes say 14 days for the detection of the suspicious activity, does the bank have 30 days from that date to file the SAR?
My question is we have a business with two separate accounts but using the same TIN. Are we required to file two designation of exempt forms in this instance? Our recent FDIC exam said yes and not that I'm doubting them I wanted to find out for sure. If we report the same business name twice with the same TIN it seems like one form would wash out the other form.