Also, the client reported the fraudulent checks 10 months after statement cut which is deemed late according to our account agreement. Is a bank obliged to reimburse a consumer client for a fraudulent check paid out of their checking account? (We are in New Jersey.). If we price HELOCs based on the applicant's credit score and loan to value ratio, so some borrowers get a lower rate than other borrowers, can we disclose the lower rate in our advertisement, or do we need to disclose both rates? Do we also need to specify the criteria for receiving the lower rate? Reimbursing Paid Fraudulent Checks Is there a regulation/law for Trust Departments holding common stock certificate's for clients where it must be the physical copy or is a digital scanned copy acceptable to have on file to verify? Now that banks can participate in lotteries, can we facilitate raffles unrelated to the bank for local service groups- post lobby posters or sell tickets for or be a sponsor, etc.? Holding Stock - Original or Copy It looks like some really big deductions are held by the employer. We have a customer who is a young and receives a very small paycheck. Do we need to add the cash back amount to the reportable CTR? Big deductions on paycheck red flag for human trafficking? The POS transaction happened after banking hours. I found out that our client did a POS and got cash back. Is this necessary? Currency Transaction Report Filed by MistakeĬan you tell me where to find guidance on, or when to actually do, when a Currency Transaction Report was filed by mistake? Currency Transaction Report Filed by MistakeĬan you tell me where to find guidance on, or when to actually do, when a Currency Transaction Report was filed by mistake? Add Cash Back Amount to Reportable CTR? We continue to collect information regarding deposits over $10,000.00 from our customers who have a CTR exemption. How do I handle Part III of a CTR if part of the withdrawal was at a branch and the other part was through an ATM at another location? The total cash amount exceeded $10,000.00 in one day. Is this necessary? Part III of a CTR- ATM at Different Location How would you complete the CTR in this situation: is there only one Part 1 (customer) or two Part 1 (customer and family member)? And the $7,000, would be under negotiable instrument and $13,000 under fund transfer? The reason stated was that they are in the process of buying a house and escrow wanted him to show the proof of funds in a statement which was the reason for the transfer. He is not on the family member's account. He returned later the same day with an account number of a family member and wanted to transfer $18,000 using the cash deposit and preexisting funds from his account. He then wanted to purchase a cashier check for $7,000. The funds were first deposited into his account. The teller inadvertently runs the transaction twice resulting in software showing a $16,000 total withdrawn. If a customer doesn't truly deposit or receive over $10,000 in cash, but a bank transaction error causes it to appear that they did, should a CTR be filed or should the transaction just be documented appropriately? Example: A customer withdraws $8,000 in cash. So in short is there a regulation stating that banks need to exempt customers, or why is it done? CTR for Bank Error We just filed CTR's on large cash transactions. 2023 BSA/AML Top Gun Conference ON-DEMANDĪre banks required to exempt customers for CTR filing limits? I've worked for banks in the past that never exempted anyone.2023 Lending Compliance Triage Conference.2023 Operations Compliance Triage Conference.
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