Manager at a bank ($490MUSA)
We've had a few customers exhibiting strange ACH credit/debit behavior with Robinhood; multiple credits equalling tens of thousands of dollars coming into our checking account, then multiple debits back out to the Robinhood account a couple of days later. The process then repeats. Has anyone else seen this kind of behavior or know the logic behind it? I know Robinhood offers "instant deposits" where you can access your funds immediately after scheduling a deposit, but I'm not sure how this back and forth would benefit a customer. 

Alternatively, if anyone has a fraud contact at Robinhood who may be able to discuss further details we'd love to have it!

Debit Card Fraud

Manager at a bank ($54MUSA)
We have a customer that is claiming fraud on their debit card --- They are a shop-acholic --- They are claiming they don't remember ordering these weight loss cleansing pills -- but they called the company and it looks like a subscription was signed up for and they sent them the product --- They told them that they can prove they received the product --- Do we go ahead and initiate the dispute?  Do we have to give them provisional credit?  Or is this something that we can deny?   Any help would be appreciated.   Thanks in advance.

Complaint Management

Person at a bank ($218MUSA)
Good Afternoon All!
I am doing policy review and have discovered that we have a Consumer Complaint Policy  and it is also embedded within our Compliance Policy. My guess is that at some point an auditor may have recommended we have a separate policy for Consumer Complaints - maybe? Do I have to have it in both places?

Check Cashing Business

AVP at a bank ($1BUSA)
We have some local check cashing  businesses that bring in checks written to the business drawn on us.  They want us to run the checks and give them a cashier check for the total payable to the check cashing business.  This has been a long time practice. I think that we need to stop doing it or at least charge for it. 
Does anyone else do this or have any thoughts on it?

Thank youo

Compliance Department Reporting Structure

VP at a credit_union ($768MUSA)
We are reviewing the current positioning of Compliance with the credit union, and your input on these questions  is very helpful.  1) Where does your compliance department fit within your organization chart/what is the reporting structure?  2) What the title of the person leading your compliance program? 3) Number of compliance staff? 4) What is the asset size of your credit union?   Thank you for your time and response.

CIP on Account Signers

Manager at a bank ($369MUSA)
I would like some feedback about what you do under your CIP Policy for signers on a deposit account that aren't the account owners.  Currently, we get their DL and SSN and screen for OFAC, Red Flags and risk. Pretty much what we do for owners. I'm getting some pushback from the line of business about the identification and address verifications we're doing. They are telling me that everywhere else they've ever worked, all they did was run OFAC, get a copy of the DL and record the SSN on the system. What do you do at your bank?