FINCEN NOTICE OF UNEMPLOYMENT FRAUD

Chief Compliance Officer at a bank ($326MUSA)
We received notice of unemployment fraud earlier this week.  We discovered this fraud yesterday in an account holders checking account.  I understand I am to include COVID 19 in the SAR narrative .. I am to include in field 2  “COVID19 FIN2020-A002” and select SAR field 34(z) (Fraud-other).   I am unclear if I am to call  the National Center for Disaster Fraud (NCDF) hotline (1-866-720-5721).   I believe I will do so.  Has anyone else discovered these funds.  Did you return the funds?  ( Since laws regarding unemployment vary state to state I am confused ) or did you put a hold on them?  What eventually happens to these funds.  I am also wondering if I should file the SAR today - or wait a couple of days to see if more transactions occur before filing.  I would love to know how other banks are handling this. 

Jack Henry Open Anywhere, Q2 Gro for Online Account Opening (OAO)

AVP at a bank ($741MUSA)
We are considering moving away from Bottomline for OAO (online account opening).  We are a Jack Henry Silverlake core with Q2 Software for online banking, so we are considering JHA Open Anywhere and Q2 Gro.  

I am looking for feedback on these two OAO product offerings.  Specifically how long you have been on the respective OAO platform, implementation experience, back-office experience, end user (customer) experience, compliance issues, examination issues, account funding issues, disclosure issues, reliability/availability issues, core compatibility issues, billing/accounting issues, ID verification/authentication interface, product support issues?  Do you have an SLA and have you ever had to invoke your SLA to obtain/enforce a penalty?  I would appreciate any information on the two OAO product offerings.  We, like everyone else, just want to make an informed decision.  Thanks in advance.

BSA monitoring report

Employee at a bank ($247MUSA)
What is your error rate regarding branch personnel inputting CTR data? Whether that is to a form that an Analyst uses to complete and file the CTR, or directly into your BSA software? I would like to see and possibly reference in my monitoring report how our bank compares to other FI's regarding error rates. What about CBO and CDD completion also?

Thank you to all who are willing to share!

Call Center

AVP at a bank ($1.1BUSA)
We are a community bank that is starting an official call center. Previously our Backoffice employees answered our customer calls that did not ring to a banking center. I'm looking for any policy and procedures that anyone would like to share. Does anyone have a incentive program for their call center? If so, what is it based on? We currently use Cisco but would like to look into other call center programs. Any suggestions are welcome!


CTR Question

Employee at a bank ($283MUSA)
I'm sure I am overthinking this...but...

Husband and wife come in together. Husband has a check payable to himself for $10,500.00 to cash and wife wants to withdrawal $10,000.00 from their joint  account (she signs withdrawal slip). They want all cash back as one lump sum. (ran as one transaction) 

When filing the CTR, do I mark each of them as conducting on own behalf with the total that each requested on line 22? 

Sorry. My brain is in overdrive today!

Input of New Deposit Account Info

SVP at a bank ($82MUSA)

**I will say we are a small bank, but we allow a new accts employee to take information and prepared the customer's documents and then allow that same employee to input the new account information in the online system. We do have a separate employee that gets a new account report with this new information the next day and then this "other" person then reviews what was input referring to the documentation (at least they are supposed to be referring to the documentation-but there are situations in which all the documentation might not be available when the account is reviewed.). However, this process is being questioned. Should whoever opens the account not be allowed to input the information into the system?

TRID Purpose

Employee at a bank ($99MUSA)
Please help me determine the TRID purpose for this loan.  

We already have a mortgage on the vacant land.  The new application is for refinancing the current land loan and purchasing a mobile home to sit on the property. 

I was initially assuming "purchase" since we are purchasing the mobile home, but after researching it sounds like it would only be considered purchase if we were purchasing the land with the new loan because we don't list the mobile home at the top of the LE where the property address is.  So is this loan "purchase" or "refinance"?  Is it only the property address on the LE that the loan purpose is referring to?  We do list the mobile home on page 4 of the CD under "security interest."

Thank you!

As a follow-up, how does this effect my HMDA purpose?

Section 1112 Debt Relief

Chief Compliance Officer at a bank ($73MUSA)
On Colson's website under the CARES Act tab, there is an item called "Section 1112 Debt Relief" and you are suppose to input gross loan payments.  Is that only for the 7(a) SBA loans  customers had that their payment was "paid" by SBA?  We only have PPP loans so I am thinking I shouldn't have to do anything with this, is that correct?  I have completed the other two columns under Lender Certifications and Payment Instructions, just not the 1112 column.