Retail Risk Monitoring Compliance Interviews

BSA / AML

100

What does CTR stand for and when would you use it?

Currency Transaction Report- filled out for all transactions over $10,000

200

What does AML stand for? Give an example of what they look for.

Anti-Money Laundering

Ex- Large cash deposits from unknown sources, wire transfer large amounts of money to secrecy and tax havens, large deposits immediately followed by withdrawals of almost the same amount or receive many small incoming wire transfers or deposit checks and money orders and then order a large outgoing wire transfer, etc

300

What is a SAR? When do you use it?

Suspicious activity report.

Fraud, potential loss for KeyBank, threat to the safety of people or facilities, BSA-related activity, and any other suspicious activity (even if carried out by a good or well-known client).

400

What does BSA stand for?

Bank Secrecy Act

500

Give a general overview of the BSA.

The BSA consists of a number of record keeping and reporting requirements designed to overcome foreign bank secrecy laws and to identify the movement of large amounts of cash. Large cash transactions are frequently associated with criminal activity, and the reports filed under the BSA help the Department of the Treasury identify people engaged in criminal activity, such as dealing in drugs or laundering money for drug organizations. The five major areas of the BSA cover:

• currency (cash) transactions over $10,000
• cash purchases of bank checks, drafts, money orders, and traveler's checks in amounts from $3,000 to $10,000 (inclusive)
• international transportation of currency and monetary instruments
• record retention and taxpayer identification number (TIN) requirements

Reg CC

100

Can you place a Reg CC hold on a KeyBank check, Money Order, or OBC?

No

200

What must you give to the client when a Reg CC hold is placed?

• If the client is present when you place a hold, you must obtain the client's signature on the hold notice, either by using the CAD or by having the client sign the Hold Notice Signature document.
• If the client is not present when you place the hold, you must mail the hold notice to the client no later than the business day after the day you placed the hold.
• For every hold placed, Teller21 prints the Case-by-Case/Exception Hold Notice form, which indicates the duration and the reason for the hold. You must provide the client with the printed hold notice

300

Can we place holds when cashing Not-On-Us Checks?

Branch teammates can place a two-business day Reg CC hold on an account of recourse when cashing a not-on-us cashed check. Used at the branch's discretion, this hold type, referred to as "pledge hold" in Teller21, can protect the bank from losses associated with the return of a not-on-us cashed check.

400

What are the types of Reg CC holds placed automatically by Actimize?

Large Deposit: An automated large deposit hold can be placed on an individual check in an amount of $6,725 or more, with only the amount over $6,725 being held. The duration of the large deposit hold is no more than seven business days 

Reasonable Cause: An automated reasonable cause hold can be placed on an individual check for the full amount of the check. The duration of the reasonable cause hold is no more than seven business days.  

500

What is Reg CC? How do Reg CC holds work?

Regulation CC requires banks to make funds deposited into accounts available to clients within a prescribed period of time.

To help ensure that banks can collect on deposited items, Regulation CC permits banks to place holds on deposits to decrease, for a specified time, the account balance available to clients. Regulation CC:

• defines the types of holds that banks may place (the two general types are "case-by-case" and "exception" holds)
• describes the circumstances under which the holds may be placed
• limits the duration of the holds

Regulation CC also requires banks to disclose their funds availability policies to clients and to notify clients whenever banks place case-by-case or exception holds on deposited funds. KeyBank has established a funds availability policy in compliance with Regulation CC.

Reg DD

100

Does Reg DD apply to business entities including sole proprietorships?

No

200

What is Reg DD?

Regulation DD is a federal regulation that implements the Truth-In-Savings Act. The purpose is to allow consumers to comparison-shop for deposit accounts.

300

What are we required to do under Reg DD?

Regulation DD requires financial institutions such as KeyBank to prepare account disclosures for each deposit account that will be offered to consumers. The major provisions of the law require KeyBank to:

• provide consumer account holders with written information about important terms of an account, including the annual percentage yield (APY)
• provide fee and other information on any periodic statement sent to consumers
• use certain methods to determine the balance on which interest is calculated
• comply with special requirements when advertising deposit accounts

400

Who is Covered by Regulation DD?

Regulation DD covers any consumer (natural person) who maintains or establishes a deposit account primarily for personal, family, or household purposes. It also covers unincorporated associations of consumers (natural persons).

500

What accounts are covered by Reg DD?

Regulation DD covers all deposit accounts offered by a depository institution. At KeyBank, this includes the following types of accounts:

• personal certificates of deposit
• personal checking accounts (including accounts that bear interest and accounts that do not bear interest)
• personal checking plans
• personal retirement accounts
• personal savings account
• personal money market accounts

Reg Z / Managing Risk

100

Name at least three types of fraud.

Account takeover, ACH fraud, ATM or debit card fraud, Bill Pay fraud, Check fraud, CC fraud, Elder abuse, Phishing, Identity theft, Internal fraud, Wire fraud, etc

200

What is your responsibility when handling potential fraud?

KeyBank must report suspicious or illegal activities whether or not we sustain a loss. If we fail to report these activities, KeyBank could pay extensive fines.

300

What is Internal Fraud? What is your responsibility to the situation if you suspect Internal Fraud?

Internal Fraud is any unauthorized or illegal activity committed by employees against their employer. 

If you suspect Internal fraud, it is your responsibility to report it (use the Report It! tool)

400

What is the timeframe in which disclosures must be provided to a client who is in branch and applying for credit? What is the timeframe for a client who is not present for the application?

Client present- Immediately

Client not present- Three business days

500

What is Reg Z?

Reg Z, AKA the Truth in Lending Act, is to promote the informed use of consumer credit by requiring disclosures about its terms and cost. The federal government requires that disclosures be provided to borrowers to:

• help explain the complex nature of a loan transaction
• inform the borrower of the term and costs of the loan
• advise the borrower of his/her legal rights and obligations associated with the loan

UDAPP

100

What does UDAPP stand for? 

What is UDAPP?

Unfair, Deceptive, or Abusive Acts or Practices 

UDAAP is Section 1036 of the Dodd Frank Act that prohibits any provider of consumer financial products or services from engaging in unfair, deceptive or abusive acts or practices. The regulators established UDAAP to ensure all consumers are treated fairly by financial institutions in their marketing, sales and servicing practices.

200

What are Deceptive Acts or Practices?

An act or practice is deceptive when:

• The representation, omission, act, or practice misleads or is likely to mislead the consumer;
• The consumer's interpretation of the representation, omission, act, or practice is reasonable under the circumstances; and
• The misleading representation, omission, act, or practice is material.

Deceptive acts or practices can take the form of incorrect representations concerning a product or service, such as its price or cost or an omission of information. The consumer's reasonable interpretation is measured on how a reasonable member of a target audience or a majority of an audience would interpret the representation.

Deceptive acts or practices are material if the information is important to the consumer, or it is likely to affect a consumer's choice of, or conduct regarding, the product or service.

300

What are Abusive Acts or Practices?

An act or practice is abusive when it:

• Materially interferes with the ability of a consumer to understand a term or condition of a consumer financial product or service; or
• Takes unreasonable advantage of a consumer's:
  • lack of understanding of the material risks, costs, or conditions of the product or service;
  • inability to protect their interests in selecting or using a consumer financial product or service; or
  • reasonable reliance on a covered person to act in their interests.

Although abusive acts also may be unfair or deceptive, the legal standards for abusive, unfair and deceptive are separate.

400

What are Key Employee Responsibilities in regards to UDAPP?

Key employees are responsible to ensure current and prospective clients are given accurate information about rates, fees and other terms and conditions about a product or service. Employees should always confirm that the client understands the terms and conditions of a product or service.

Key employees are expected to address routine inquiries, complaints and questions from clients regarding their accounts at the point of contact and resolve them in a courteous, expeditious and satisfactory manner.

500

When explaining a marketing premium offer to a client, what should you reference and how should the conversation sound?

-Clearly go over marketing premium and explain the way to qualify

-Go over all disclosures, ensuring the client is clear of the offer they are receiving

-Give client a copy of the marketing offer and disclosures