ACH Debit & Credit Blocks

SVP at a bank ($4.9BUSA)

Thank you for reading my request!  I am looking for a sample ACH Debit and/or Credit Block form that you use when a customer (example; attorneys) request that you not allowed any ACH debits (occasionally they ask about credits) to hit their account.  I know there are several vendors that offer this through their Positive Pay programs, but many of these customers do not want to use Positive Pay.  We have checked with NACHA and they do not have a sample and suggested we have them sign a disclosure but could not provide guidance on that disclosure; contents, etc.  If you have such a form and would be willing to share it would be appreciated.  Thanks and have a great day!

Interactive CIP Form

Manager at a bank ($780MUSA)
Does anyone know of a software/program that offers an interactive CIP form? We are looking to create some type of interactive CIP form. Somewhat similar to Yellowhammer/DDM. 

affirmative consent

Person at a bank ($525MUSA)

I.T. feels that affirmative consent can be given by customers for e-statements in our lobby on their mobile devices. They feel that if they can demonstrate to account opening person that they can access our website and open a PDF file that this should be affirmative consent. I say no, because we need to provide hardware and software needs/ let them know they can still get paper disclosures, how to opt-out and what transaction this applies to. Additionally we would not have an electronic consent or confirmation electronically. I say we need to continue with our email that contains all this information and gives the customer a way to electronically consent. Does anyone else feel any differently

Reg E Dispute

Employee at a credit_union ($160MUSA)
We had a member who was getting unauthorized charges on her debit card since Sept 2018. The member just let us know a few days ago that this was happening, therefore these charges have accumulated over the last year. Charges were from Lyft/Uber and the member is 89 years old, no POAs/joint owners on the account. Our research thus far indicates this is indeed fraud. Card has since been shut down immediately.

According to a chart on this website, my understanding is that we wouldn't be responsible for anything over the initial 60 days in 2018. 

The question is, for that first sixty days (lets say Sept 1 2018 - Dec 1 2018), are we responsible for the full amount of the fraudulent charges or can we hold the member responsible up to $500? At first I was thinking we could hold them responsible up to $500 but now that I'm looking more closely, I feel as though we cannot. Any thoughts?

Correcting HMDA

Employee at a credit_union ($857MUSA)
Question for the group. in managing HMDA reporting, do you do HMDA daily, weekly, monthly? When you do the reviews, how do you manage errors? Do, you correct the LAR only? Do you correct the LAR & system? Do you have a specific group that cleans and correct? Do you send back loans with HMDA errors for the users to correct?

We have a very high error rate on HMDA loans even though there has been a number of trainings this year. I would like to see how others manage their HMDA reporting each month and the procedures you take to correct.


Altered Check Fraud

Manager at a bank ($118MUSA)
So I had a business customer balancing their statement from last month and they came across several checks that had the payee altered from the bills he was paying. We returned them "altered/fictitious" and one of the bofd has sent us back a "Claim of Late Return". I'm not sure what options I have here, my compliance officer is on vacation. Can anyone help me?

SAR Advise

AVP at a bank ($1BUSA)
In Feb. we had a customer that had several large fraudulent checks coming into her account. We stopped them, closed the account and filed a SAR.  Now we are receiving cashier checks with our bank name on them with our customer's old checking account number on them (payable to multiple people at different banks). They total over $25,000 so far. I know that I need to file a SAR. My question is: do I  amend the previous SAR or reference it in the narrative or just file a new SAR since she has closed that account??

Thank you