Bank Secrecy Act
This is the name of the Bank's BSA/AML/OFAC Officer.
Who is Jody Crowley?
This acronym refers to the Customer Identification Program.
What is CIP?
US Patriot Act Signs are posted in the lobby and in new account disclosures for both loans and deposits.
True/False
It is permissible to notify a customer that a SAR has or will filed on them?
What is False?
You should never indicate to a customer that a SAR will or has been filed. In fact if you are asked your answer should be "What SAR?"
Access to information regarding SAR's that the Bank has filed is extremely confidential and should not be disclosed. Certain law enforcement agencies may request information regarding a SAR but in other instances it may be necessary to notify and request permission from FinCEN to disclose the existence of a SAR.
Cash transactions involving more than this dollar amount that trigger the filing of a CTR.
What is a $10,000.00?
Cash transaction(s) for exactly $10,000.00 would not be filed.
Cash transaction(s) for $10,000.01 would be filed.
It's okay for me to leave documents with confidential customer information out on my desk. I'll be the first one into the Bank in the morning.
What is False?
When you leave for the day you should look at your desk to make sure all confidential customer information is protected.
Retrieve print jobs from the printer when you print.
When you leave your desk you should use the Microsoft Windows key + L to lock your screen so no customer information is visible. This is especially important if you have a customer at your desk.
What sign is required at any desk where a deposit can be accepted?
What is the gold FDIC Insurance sign?
If you have a lender or personal banker that has customers that frequently drop off deposits in their office, they should have a sign. Please let Jody know if additional signs are needed.
There are several other signs that are required to be displayed in the lobby but this one is specific to physically accepting a deposit.
It is acceptable to help a customer structure a transaction to avoid BSA reporting requirements.
What is False?
It would be seen as "willful blindness" to assist a customer in evading a BSA reporting requirement. Fines and penalties could be assessed.
True/False
It's okay to use an expired drivers license for CIP when a customer is opening a new account.
What is False?
The Banks CIP policy states we will accept an unexpired State issued ID or a passport.
What do I do when I see suspicious activity or behavior and how do I communicate it?
What is an Unusual Activity Report?
This is located on the shared drive under Compliance/Forms and should be sent to the Banks Compliance Officer.
Any information regarding suspicions is important no matter how big or small it appears to be. If you think it looks suspicious, report it. You will never be criticized for submitting an Unusual Activity Report, in fact it is welcomed.
It is important to keep this information confidential and should not be discussed amongst coworkers.
Certain customers can be exempt from CTR reporting by filing this form.
What is a Designation of Exempt Person form?
Not all businesses are eligible to be exempt. For example car dealerships and businesses that receive more than 5% of their annual revenue from gambling activities (pull tabs).
CTR filing is not restricted to just Banks. Credit Unions, Casinos, car/plane/boat dealerships are all examples of other businesses that are required to file CTR's.
True/False
If I am the first person to get to the Bank in the morning and someone is waiting at the door I should open the Bank and invite the person in and offer them a cup of coffee.
What is False?
You should not enter the bank and instead call 911 to explain you are a bank employee opening the bank and there is a suspicious individual near the entrance.
TIP: It's a good idea to have fellow employee phone numbers in your cell phone so you can notify them of what is happening.
True/False
A customer calling to complain that our fees are too high is a complaint.
What is False?
A customer making a general comment that our fees are too high is generally not a complaint.
We need to be able to realize when someone is making a comment or making a true complaint. A true complaint might be someone saying they didn't feel they were treated fairly by a bank employee; an individual who might be trying to open an account and the employee isn't being responsive. It's hard to offer a list but use your best judgement. Always feel free to pick up the phone and call the Compliance Officer. It's better to discuss than not report.
This is the name of the report that is required to be filed for cash transactions involving in excess of $10,000.00.
This could be from a cash deposit or withdrawal or even proceeds from a loan or wire transfer just to name a few.
What is a Currency Transaction Report?
The Bank has 15 days from the date of the transaction to file the report.
Our Bank is the only bank required to collect information such as legal name, date of birth, physical address and identifying number. No other banks ever request such information from their customers.
What is False?
All Banks are required to obtain and retain this information. The retention period is five years after all accounts tied to this individual are closed.
True/False
If you notice something that seems suspicious you should keep it to yourself until you have more details. You don’t want to draw attention to it until you have all the facts.
What is False?
You should notify the Compliance/BSA Officer of your suspicions as soon as possible. There is a 30 day time frame from the initial point of discovery for reporting purposes.
True/False
A customer cashes a check for $15,000. Later that same day he returns to the bank and deposits $12,000 in cash to his checking account. No CTR would be required because the net cash received by the customer at the end of the day is only $3,000.
What is False?
We do not net cash in against cash out to file a CTR. The trigger is greater than $10,000 cash in or cash out. If both tests are met, both are reported.
If a customer deposits $12,000 in cash and later withdraws $300 in cash only the $12,000 cash in is reported.
Is there a duress code for the security system that I can enter instead of my own code in the event of a morning glory robbery?
A morning glory robbery is when someone forces you to open the Bank, usually in the morning as you are opening.
What is 5900?
Instead of entering your own code into the alarm panel you would enter 5900. This will send a silent alarm to the police.
True/False
If a customer refuses to give me their personal information such as social security number or date of birth I can still go ahead and open the account.
What is False?
If a customer refuses to comply with our CIP policy, you should refuse to open the account. Further you should forward any documentation via an Unusual Activity Report and information to the bank's Compliance/BSA Officer. This may warrant a Suspicious Activity Report to be filed.
True/False
Fines can be imposed on the Bank, directors, partners, officers and employees of the bank for BSA violations.
What is True
True/False
The Patriot Act was enacted in direct response to the September 11 attacks on the World Trade Center in New York City and the Pentagon in Arlington, Virginia, as well as the 2001 anthrax attacks.
What is True?
This was a landmark Act of the United States Congress and signed into law by President George W. Bush.
True/False
The bank must notify its Board of Directors or designated committee when a SAR has been filed.
What is True?
While SAR's are not disclosed in detail to the Board they must be told the number of SAR's that were filed during the prior period.
We report the number of SAR's filed monthly to the Board.
The SAR may be discussed with the Board so they are aware of the risk involved. For example if we had a customer that was kiting checks we would advise the board of the situation but we would not typically disclose the name of the customer(s) involved.
The bank has this many calendar days after the “business day” the reportable cash transaction occurred to file a CTR.
What is 15?
True/False
I should always provide account information to anyone that calls or comes into the Bank for information on an account.
What is False?
Prior to releasing any account information the account holder must be identified. This can be done by verifying the last four digits of the tax identification number on the account, referencing the list of authorized signers, the amount of the last deposit, the amount of a specific ACH transaction such as a car payment, insurance payment.
Take into account how young or old the caller sounds as compared to the date of birth we have listed on the system.
True/False
If a check is made payable to Bob AND Jane Smith, it's okay if only Bob endorses the check if they deposit it into a joint account.
What is False?
All payee's must endorse a check if the word AND is included between their names. If OR is used, then one signature is sufficient.
Be especially cautious on government and insurance checks. They watch endorsements very carefully and will return the check if one of the signatures is missing. The bank could be at risk if they have written out checks against this money and there is nothing to charge back against.
The Bank has a guaranteed endorsement stamp but caution should be exercised when using this stamp as there is added risk due to the possibility of fraud.
True/False
There are three steps that occur in Money Laundering.
What is True?
The three steps are: Placement, Layering and Integration?
Placement: Getting illegal funds into the legitimate financial system. Putting "dirty money" into a range of different places.
Layering: Conceal the source using transactions to conceal the illicit origin of funds. This involves breaking down large bulk funds into a series of smaller transactions. This makes it more difficult to track the original source of the funds. The more you move it, the more you distance from it.
Integrating: This is the final step of making the money appear as legitimate income or assets. Making laundered funds available for spending by reinvesting them.
True/False
A customer must be given notice as to the bank's requirements to obtain and verify the customer's identity.
What is True?
There are signs posted in each lobby and disclosures are given at every account opening including loans.
The number of calendar days the bank has to file a SAR once suspicious activity has been detected.
What is 30?
The Bank must also file 90 day continuing activity SAR's until the account is closed or the activity has ceased.
True/False
The Bank must refuse the transaction if the customer refuses to supply the information required to file a CTR.
What is True?
There are many fields to a CTR but information such as name, address, date of birth, social security number are all required fields.
NAICS Codes are strongly recommended as law enforcement agencies can group by business types as they perform searches.
Examples of fields that are not required but if we have the information we should provide on the CTR would be an email address, phone numbers or website address.
The milk bone jar in the drive through at Claremont -
or-
The orange magnetic clip at the back entrance to the bank AND the two "can" lights closest to the front gate are turned on at the front entrance
What are the "all safe signals" for the branches that let other employees know its safe to enter the bank in the morning?.
True/False
If a customer calls for a rate on a deposit account (MMKT, Savings, CD, etc.) all I have to give them is the rate.
What is False?
Each and every time you quote a rate you must specifically state "annual percentage yield" for each rate quoted. You can't say "all of the rates I am quoting are annual percentage yields", you can't abbreviate and say "APY", you must specifically state the words "annual percentage yield" for each rate you quote.
The FDIC has "testers" that will periodically call and test banks on this and we can be cited with a violation if we are not in compliance with this. Even when Rate Watch calls and asks for all of our rates, it needs to be said for every rate you quote.