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In addition to the trustee, can a trust account have authorized signers?
No. Trust accounts cannot have additional signers. Only the trustee can sign on the account.
An account has two owners (i.e., husband and wife). They are in the middle of a separation. The wife wants to have the husband removed from the account. Can we permit removal of the husband from the account?
No. Both are equal owners of the account. Closing the account is the only alternative.
When using the large dollar reason for an exception hold, how much must we make available to the customer?
$5,525.
Does a church account require completion of a beneficial ownership document?
Yes. Although a church doesn't have ownership, it will need to have a controller identified on the form.
When opening a new account, the primary owner is new and the joint is existing. Can we use a "new account" hold on this account?
No. If any owner on the account has other deposit relationships, you cannot use the "new account" hold.
According to bank policy, what is the minimum age to have a checking account?
14
We had a business call to inquire about opening a new account. They are not located in our immediate banking area and just want a local community-oriented bank to open an account. They don't like the "big banks". Are we okay to open an account?
No. Account relationships, personal and business, should only be established with a local connection (the customer lives or works within our branch footprint).
An account has a single owner. A beneficiary is also listed. The beneficiary dies and a short time later the account owner dies. The beneficiaries of the beneficiary are seeking to claim funds from the account. Can we accommodate this?
No. The account owner has died, and the beneficiary has died. Beneficiaries of the beneficiary have no legal access to the funds.
In what circumstances is a 3-day hold permitted on a deposit?
There's no such thing as a 3-day hold.
A new customer has a hit on ChexSystems and owes $38.25 to M&T Bank. Can we open the new account?
Branch Managers are permitted to make exceptions when amounts owed are less than $200, as a single amount or aggregate of multiple. You can open this account, or you can decline the account and provide an adverse action.
I have a new customer who does not have a SSN. Is it okay to open the account and have the customer give us the number once they receive it?
No. Customers must have a SSN/ITIN in order to establish a relationship with the bank.
A customer's ID expired last week and they have not yet obtained a new ID. Since it expired just a couple days ago, can we open the account and follow-up with the customer to bring in their new ID once obtained?
No. ID's must be UNEXPIRED on the day the customer is opening the account (or being added to an existing account).
How is OFAC documented for a new account?
By ensuring "OFAC - Yes" appears on the signature card.
Can a bank place a hold on a cash deposit?
Yes. A bank can delay availability on cash deposits for 1 day.
If a customer disputes a transaction, within how many days must the bank provide provisional credit?
10.
We have a customer who has POA for their mother's bank account. The mother has passed away. The POA is asking to withdrawal funds for funeral expenses. Can we permit the POA to withdrawal funds for this purpose?
No. Power of Attorney ends upon death of the individual for whom the POA was created.
What is the number of days we can place a case-by-case hold?
2
What is the maximum number of days, after an account is uploaded to the system, that the account must be sent to compliance?
14.
A new business customer is opening an account. They were formed 86 years ago and do not have copies of their articles of organization. What alternative documents, if any, are permitted?
None. The customer must provide us with their articles of organization no matter how long ago they were formed.
What types of accounts do not require ChexSystems?
Some examples - minors, existing customers, trust, estate, newly formed entities.
Father and Son #1 are joint owners on a CD. Son #2 is POA for the father. The CD has reached maturity. Son #2 comes in to close the CD. Can we permit Son #2 to close the CD?
Yes. The POA (son #2 in this case) can act on behalf of the father.
After how many days of no activity does the system put an account into dormant status?
365
What is the maximum number of beneficial owners for new account purposes?
4.
My new customer is 100 years old and no longer has valid, unexpired ID. What type(s) of identification can we accept in this circumstance?
2 types of alternative identity verification are needed such as - copy of SS card, medicare card, medicaid card, piece of mail with address.
Customer is depositing $12,000 cash. Upon asking routine CTR-related questions, the customer decides to deposit $9,000 and keep the rest. Do I need to do anything because of this?
Yes. Notify BSA.