I'm the compliance officer at a small community bank. We do not offer remote deposit capture, but from what I understand, some of our bank's commercial deposit customers have gone out on their own initiative and obtained RDC services from various third parties. Our customers are then using this platform to make deposits to their accounts at our bank. This would seem to involve risks to our bank, but I'm getting a lot of push-back from the sales side, that because our bank had nothing to do with the customer's decision to enroll in or obtain these RDC services, the bank has absolutely no risk. I'm not as convinced about that. Any help and or guidance appreciated.
While reviewing a suspect fraud journal I noticed suspicious activity on one of our customer's debit cards. Only after contacting the customer did we learn the card had been left in a restaurant ten days earlier. The customer knew they had left the card, but failed to report it as lost or stolen. Are we responsible for charges incurred ten days after the customer was aware they had lost the card?
I have been told that the employees in charge of on-line banking are considering allowing wire transfers through our new on-line banking product. What kind of compliance and security issues should they consider when they are designing this product? We are new to on-line banking so my feeling is that we should learn to crawl before we run. Some of the bigger banks do not have this on-line banking feature. How does our midsize bank think they have the resources and the knowledge to accomplish this?
Our bank customer got "phished" and his Internet authorizations were compromised. Thieves used his password to access our website and the customer’s account info and they initiated instructions for the bank to issue checks (probably to an accomplice). These checks are vendor checks. The payee cashes them at any check cashing business. When the customers realizes the suspicious activity and notifies bank, we place stop payment orders on the vendor checks but only after some have been cashed by the payee/accomplice. The check cashing business made a demand on the bank for the funds. Who bears the loss and is there a UCC or CFR provision that addresses this issue?
We issue Visa debit cards. We monitor for suspicious activity such as excess cash withdrawals, excessive denials for cash withdrawals and rejection of PINs. Should our disclosures and applications state "the account can be closed at our discretion"?
The American Bankers Association and the American Bar Association recently held their 14th annual Money Laundering Enforcement Seminar.