We had an individual come in to open a new account. They had an out of town license, out of town tag on car, out of town address on a Treasury check and wanted cash back. We said no for various reasons and they left. Later a policeman who banks with us came in. The teller told him about the situation and he asked for copy of the license and check (which the teller provided). He ran the license and discovered there were multiple warrants out for arrest of the person. Later our CFO freaked and said the teller violated laws by providing the info to the policeman. I was wondering what laws were broken and if we are opened up for a lawsuit.
My customer bought three cashier’s checks for $10,000 each and the checks are still outstanding and have been for a while. Do I need to let my BSA Officer know?
Recently, our New Accounts has opened a few Guardianship Accounts. They have the proper documentation but we believe that the accounts may be under the incorrect social security number. What social security number should the account be filed under? Is it the Guardian (representative) or the Guardianship (beneficiary)?
During one of our recent exams, it was suggested by the examiners that we open accounts online (which surprised us); they would like us to phase out our brokered deposits and felt we could replace these deposits by opening accounts online. I have been trying to gather some information on what is involved in opening accounts online, in particular the risks involved; how to handle CIP, how to handle disclosures and how to obtain the initial deposit. I put out a question on Banker Threads, but did not receive much information. Can you direct me to any information that would help?Also, our president would like me to do a comparison to Free Checking - the pros and cons vs online accounts. While I have not experienced opening accounts online, I have been at a bank (some years ago) that offered free checking and we had a good experience. Few losses, customers really liked not having to worry about a maintenance fee, and the average balance tended to be around $3,000. I was wondering if you could direct me to any other sources that might be able to provide information or statistics on free checking?
Can you tell me if signage for the USA Patriot ACT must me at a certain size, color, etc and must it be posted at teller window's and at new accounts desks, or can it simply be posted in a main area of the branch?
We have a CTR question. We have an exempted company that has recently opened two new accounts for a new store that just opened yesterday. Would these new accounts be automatically exempted?
Currently we do a social security verification or a credit report on all new accounts to verify identity/and/or other information. Some reports verify the individual information to be the same as what we have on the person but will not verify that the social security number is actually issued to that person, but gives the date of issue and the state issued in. According to the CIP rules, are we required to verify that the number given is actually issued to that person? If so, do you know where or how to obtain that specific information?
I contend that since we have the capacity to create CIP files on both personal and business accounts, that we should be doing just that. Our new accounts people feel that since we maintain files on the businesses with the critical documentation included there is no need to set them up in the CIP system. Am I correct or is New Accounts, correct?
I have been posed with a record retention question regarding documentation that both a CIP and OFAC was completed on. These are internal procedures that our operations department have set up themselves and is above and beyond what I can find the regulation actually stating. Is there any guideline as to how long we need to keep such extra documentation?