EIP cards for multiple people

EVP at a bank ($47MUSA)
How are you handling EIP cards that are issued to couples?  Both people's names are on the card - normally for tax refunds we would require both people to be present to cash a refund check.  Typically, when the IRS issues cards for refunds, they issue one card per filer with access to the same pool of money.  But at least they both could access it.  With these EIP cards, whoever gets to the mailbox first, can take the money and run, if only one person is allowed to withdraw it.

So, are you allowing only one of the people listed on the card to withdraw the cash?  Or are you requiring both people to be present? 

Unemployment Fraud

Manager at a bank ($220MUSA)
After researching ACH transactions today, we had a hit on an account located in Wisconsin that had 3 ACHs from WA unemployment.  I have held the remaining funds and I guess wondering next steps that should be taken.  At first glance I thought a CTR should have been filed for withdrawals however see that one trans for $2500 was cash and the other was $8200 withdrawal that was then put into a Cashier's Check.  CC has already cleared our bank but not sure if funds would still be in the other FI.  Should I reach out if they are 314(b)? Will FIs where the ACH was deposited be responsible for lost (withdrawn) funds?  

Vendor Risk Levels

Employee at a bank ($160MUSA)
Hello, we are revamping our vendor management program. I am curious what others are doing for their risk rating levels. We currently just have Low, Medium, and Critical but I am considering moving to a 4 level ranking system. What do you all think? What do you do?

Critical: The product or service provided by the vendor is critical to ongoing operations of the institution, or the vendor has access to significant amounts of non-public information that, if compromised, would pose significant hardship on the institution. 


High: The product or service provided by the vendor is required for ongoing operations but could be replaced without significantly impacting business operations. In addition, this category may include third parties that have access to non-public data in limited quantities, such as outside audit firms. 


Moderate: The product or service provided by the vendor is considered secondary or incidental to the Bank’s daily operations. The Bank will be able to operate at satisfactory capacity and deliver an acceptable level of service if the vendor fails or becomes impaired. 

Low: The product or service provided by the vendor would not cause business operations to be affected if the vendor fails or becomes impaired or does not expose non-public information outside of the institution.

Charge Off Checking

AVP at a credit_union ($175MUSA)
We are looking at changing up our process to streamline things a little better for our collectors.  A question came up asking if a member comes in and pays on their charge off (but not the full balance due), is there something that says the payment has to go to the negative balance or fees first?