Manager at a bank ($227MUSA)
We have a customer that is basically a small dollar lender, as well as a payday lender.  They issue money orders through MoneyGram in amounts exceeding $1,000.  They claim that they do not have to register as an MSB because they are issuing the money orders through MoneyGram, who is a registered MSB.  They also issue stored value cards through NetSpend, and claim that NetSpend is a registered MSB, so they do not have to register.  Does this sound right to anyone?  I guess I was always led to believe that if a business issued money orders or traveler's checks (or cashed checks) in excess of $1,000 per person per day, that they had to register and have a BSA policy and procedures in place, regardless of if it was as an agent for someone else.

Tri-Merge or Single Credit pull

Employee at a bank ($273MUSA)
It was recently brought to my attention that a lender at our bank has been pulling tri-merge reports on all applicants regardless of loan type.  We usually only pull tri merge for real estate and just a single bureau for all others.  The other lenders are following this procedure.  Should I be concerned that this lender is pulling a tri merge on all?  Or am I worried about nothing?  FYI-we do not charge for credit reports other than on real estate loans and we do not price based on credit score.

SAR for structuring or not

Person at a bank ($158MUSA)
Just wondering if others would file a SAR on the following scenarios.  Customer withdraws $6,000.00 cash from the same account two days in a row.  Looking at the account you can see that the money is from State and Federal tax return or from a insurance check.  If you know where the money came from is a SAR still required because they took cash back to back days, under the CTR threshold?

Finally, Some Great News - Removal of the FDIC's Part 350 Annual Disclosure Statement Requirement

SVP at a bank ($327MUSA)

On March 8, 2019, the FDIC Board approved a final rule rescinding and removing Part 350 of the FDIC’s regulations, which is entitled Disclosure of Financial and Other Information by FDIC‑Insured State Nonmember Banks.  The FDIC is taking this action to simplify its regulations by eliminating unnecessary or redundant regulations, which is consistent with the objectives of Section 2222 of the Economic Growth and Regulatory Paperwork Reduction Act of 1996.

Paid Off Mortgage Loans

VP at a bank ($168MUSA)
I have reviewed several record retention manuals and still have a few questions regarding mortgage loans.  We are a one office bank and our loan files are all kept in a paper format.  Once a loan is paid off, we are trying to figure out what documents are required to be kept.  We have been keeping a copy of the application, note, mortgage, rescission, copy of release, TILA/HUD or LE/CD, appraisal/evaluation.   We also keep income and credit since ATR/QM rules came out.  Does anyone else keep copies of these or do you keep more than this and if so for how long?  Any insight would be appreciated. 

Loan Policy Exceptions

Employee at a bank ($359MUSA)
Hello.  I am curious to know how banks handle loan policy exceptions.  For loan officers that have individual lending authority, and they do a loan that has a policy exception, whether it be LTV, rate, term, etc., is that loan officer allowed to approved those exceptions or do the exceptions have to be approved by a higher up?  Like a senior lender?  And what is your reasoning for doing that?  I am new to my current bank and they allow loan officers to approve their own exceptions, so long the loan is within their lending authority and the customer is risk graded under a certain threshold.  I do not agree with this, but having a hard time getting them to understand my stance.  Any feedback would be greatly appreciated!