I filed a SAR on behalf of our customer in June of last year. I reviewed the personal account within 90 days and found there was no further suspicious activity. The customer closed their account soon after. The same customer opened a business account (LLC) a few months later. I recently detected suspicious activity in that account as well. I have 2 questions: 1. Do I file the SAR under the customer's name or the business name (he is the sole owner)? 2. Even though it has been well over the 90-120 day period, do I file a continuing SAR? Thank you in advanced for the comments.
Does any one have a summary of Lending Regulations (consumer and commercial) that can be used for loan officer refresher?
Attached is section 215.4 from Reg O. The question at hand is this. If a Reg O individual has a 2 year line of credit. A draw on the line of credit is requested in month 15 of the term, does that draw need to be approved at the board level because the line hasn't been reviewed at the board level within the last 14 months? My thought is that Reg O requires the board to "re-approve" these loans and lines at least annually and giving 14 months in the reg takes into account any time lag in getting the loan/line re-approved. Bottom line, I believe all Reg O loans have to have some sort of "re-approval" annually by the board. Thoughts?? Thanks in Advance. § 215.4 General prohibitions. (b) Prior approval. (1) No member bank may extend credit (which term includes granting a line of credit) to any insider of the bank or insider of its affiliates in an amount that, when aggregated with the amount of all other extensions of credit to that person and to all related interests of that person, exceeds the higher of $25,000 or 5 percent of the member bank's unimpaired capital and unimpaired surplus, unless: (i) The extension of credit has been approved in advance by a majority of the entire board of directors of that bank; and (ii) The interested party has abstained from participating directly or indirectly in the voting. (2) In no event may a member bank extend credit to any insider of the bank or insider of its affiliates in an amount that, when aggregated with all other extensions of credit to that person, and all related interests of that person, exceeds $500,000, except by complying with the requirements of this paragraph (b). **(3) Approval by the board of directors under paragraphs (b)(1) and (b)(2) of this section is not required for an extension of credit that is made pursuant to a line of credit that was approved under paragraph (b)(1) of this section within 14 months of the date of the extension of credit. The extension of credit must also be in compliance with the requirements of § 215.4(a) of this part. **(4) Participation in the discussion, or any attempt to influence the voting, by the board of directors regarding an extension of credit constitutes indirect participation in the voting by the board of directors on an extension of credit.
Does everyone print a copy of the sig card for customers? Are we supposed to per any regulation?
Do you have a list of the timelines for flood letters --- the different scenarios - or it a standard 45 days once you give them notice of either a cancellation -- no evidence of renewal -- force placing another forced place policy????
I am trying to create more of a team environment at our branches and one effective way I have heard is to create goals! What are some goals we could implement with the tellers that could be completed in a monthly/quarterly basis? Do you have incentives for the teller line that have helped across all branches? We tried an employee of the month program and that quickly fizzled. Any input would be great! We're really starting from scratch!
Would anyone be willing to share what they consider triggering events for loans?
It's so frustrating dealing with larger banks when it comes to fraud claims. Does anyone have a contact or instructions for Citibank on how to submit a Hold Harmless request? I've just spent more than 50 minutes being transferred to several different departments who all told me that they don't know how to assist. One advisor even told me to follow our normal procedures. Thanks in advance Tammi
Does anyone have a process in place to risk rate your new loan customers that don't have a depository relationship that would be willing to share? The spreadsheet that we're using on the deposit accounts may be more involved than I think we need. Thanks!
Is anyone using this as a vehicle to access their HELOC product? If so, can you give me your pros and cons, specifically risk and fraud concerns? Thanks.