11/04/2025 We have a customer who withdrew $15,000 from their account at a branch, but then another $500 from that same account via an out-of-network (foreign) ATM on the same business day. How should we file the CTR – and should we include the ATM transaction |
10/06/2025 Does the bank need to obtain a form W-9 from each of its new customers? |
09/22/2025 How long should banks keep records of consumer complaints? Our policy says two years or since the last exam, but our state law allows up to seven years. Given the risk, should we extend the retention period? |
09/16/2025 When onboarding new customers, is the bank required to check/screen whether they qualify as Politically Exposed Persons (“PEPs”)? |
09/04/2025 Would our bank be required to obtain a Certificate of Beneficial Ownership on a guarantor to a loan? |
08/27/2025 How often should delinquent borrowers receive an SCRA notice? We are aware of the first notice requirement but, if a borrower is habitually delinquent and remains 60 days past due for several periods, are we required to “re-notice”? |
08/19/2025 What are the record retention requirements for emails between employees and customers? And are we required to keep physical copies of the emails, or can we keep them solely in an electronic format? |