Disclosure Requirements
What are the verbal disclosures required when requests to WD 10k and over and we are getting them to sign a Release from Liability form? NO BWEB
1. The risks associated with carrying large sums of cash AND
2. the different alternate options that are available
What do you do if a customer tells you they have been the victim of Identify Theft?
Disputed Transaction Form (#522044 ) is to be used when an identify theft occurs. This form is to be sent to Fraud Management for review
When do you complete a UTR? When should one be completed? NO BWEB
- The Unusual Transaction Report is your opportunity to provide details of why you are concerned that a transaction or series of transactions could be related to money laundering or terrorist financing. There is no monetary threshold for making a report on an unusual transaction (and a UTR should be completed if required for both completed or attempted transactions)
what are the morning entry procedures? NO BWEB
. Upon arrival to the branch, junior and senior meet at the predetermined location. After meeting, the senior then completes a full exterior check either by walking around or driving around the branch. Doors should be checked (emergency exits), check to ensure no tampering. If there is any sign of break in, contact 911 and IRC. Provided all looks OK, senior to proceed to enter the branch and lock the key access only. If alarm sounds, disarm premise only and go back outside (locking door behind) to get junior from the meeting location, then re-enter the branch together. Approach the branch with "a high degree of vigilance" to reduce the risk of a takeover event. If alarm doesn't sound, senior to go back to predetermined location and call GSI/IRC and/or 911.
What transactions can we complete for non- customers?
CAD Equivalent allowed per day as follows:
• Cash federal government cheques - $1750 per item ($2000 CERB & CESB)
• Bill payments, including OFI credit card payments - $2999
• Cash and coin exchanges - $2999
• Sale of commemorative coins - $2999
• Cash foreign exchange - $2999
• Cash deposits to a TD customer account - $9999 (*Does not apply to deposit by cheque)
• Cash payment to a TD credit card/Other credit products - $9999 (*Does not apply to deposit by cheque)
What must be verbally disclosed to customers when issuing a new TD Personal Access card? BWEB ALLOWED
Step #11: Written disclosures, must review ATM, POS, CNP withdrawal limits & deposit hold code.
Step #12: Verbal disclosures – read the entire bolded section to the customer or BCA interviewer
What should you do if a customer claims that they believe their privacy was breached by TDCT?
Junior staff must escalate to management. Manager must email the Privacy event notification form to TD.CPBPrivacyEvents@td.com to advise of the privacy event and include as many details as possible. The privacy designate will contact you within 2 business days to provide direction
RSC> Privacy Event/Breach
What is a LCTR and when do you complete it?
Large Cash Transaction Report: Triggered when we receive cash from a customer in an amount of $10,000 CAD equivalent or more during a single transaction. Note: The identity of an individual conducting a large cash transaction must be ascertained at the time of the large cash transaction & the source of funds
What are the End of of day closing routines? NO BWEB
Once all customer have left, senior officer can begin internal premise check – no colleagues can leave during this time and engage both locks. Senior to check all rooms within branch (including those with key'ed access) – this includes the vault, coupon room, RLAN room, lunchroom, ATM, JIT, etc. (see procedure for full list). Once check completed, all other colleagues can be left out of the branch, engage both locks on the door and cash processes can begin. Senior can delegate the check to another senior officer who is Lv. 4 or higher (they do not need to hold keys or combs) however they must report back once check is complete
A customer not known to you wants to complete a debit transaction over 5K. Where or what would you reference for the identification requirements?
– If a customer has an Access Card or TD Visa on their profile, an attempt to verify the customer via PIN is mandatory. Given the transaction is greater than $5000, you will require to have 3 factors of authentication following authentication path exactly (card, pin, OTP, ID, KBQ). If card not present and PIN not verified, a supervisor must be engaged to authenticate using One Time Passcode, Acceptable ID and KBQ. In most scenarios, regardless of the number of pieces of ID, ID only counts as 1 factor of authentication. The only exception where you will be granted to allow 2 pieces of ID and KBQ to reach the 3 factors of authentication is if customer does not have TD ACS or TD Visa on their profile. **Update May 2023: Cardless pin is no longer an acceptable authentication factor for cumulative debits $5000 or greater*
When opening a personal deposit account (PDA) what are the disclosures we need to provide? BWEB ALLOWED
BONUS: What is ODP taken? what disclosures?
-Form 513832 - Financial Services Agreement (FSA)
-Form 525812 - TD Privacy Agreement
-Form 513836 -Financial Services Terms (FST)
-Form 581076 - EasyAccess Customer Confirmation and Cardholder and Electronic Financial Services Terms and Conditions (within the EACC)
-Form 513782 - About Our Interest Calculations
-Form 513796 - About Our Accounts and Related Services
-Form 801216 - CDIC - Protecting your Deposits
**BONUS**If Overdraft Protection is taken:
-Form 802484 - Overdraft Protection Schedule Form Provide the customer with their copy
-Form 800868 - TD Canada Trust Tax Residency Self-Certification - Individual (Includes Sole Proprietor), if applicable Follow this page to complete filling Tax Residency Form
What should you do if a customer requests personal information that crosses multiple product lines and you are not able to provide them the information? What must you tell them? NO BWEB
Complete the Personal Information Access Request (PIAR Form) #800662 and email to TD.PIAR@td.com . Tell the customer
1) Information will be sent within 30 calendar days by registered mail;
2) A customer resolution officer may contact you and;
3) you will be contacted in advance if there are fees associated with the request.
A non-cx wants to cash a government cheque – what are the rules? Are there any exceptions, can we refuse? NO BWEB
For non-customers we can immediately cash a Federal Government cheque in the amount of $1750
(changed June 30th, 2022) or less (per item) provided they meet ABBS ID requirements. An exception to this
limit would be the Canada Emergency Response Benefit (CERB) and Canada Emergency Student Benefit
(CESB) cheques which have an indemnity limit of $2000 (per item). You can refuse to cash a federal government cheque for the following reasons:
1. Evidence that the cheque has been altered or is counterfeit in any way;
2. There are reasonable grounds to believe that there has been illegal or fraudulent activity in relation to the cheque or other instrument;
3. The amount exceeds $1,750 (per item);
4. The cheque was endorsed or signed by a third-party;
5. The individual is unable to provide identification as outlined in ID
Requirements on the Government Regulated ID List (Form 522050). If unable to cash you must provide
them with a Letter of Refusal.
Where are the emergency meeting locations?
1) condos across street
2) shoppers
How do you authenticate your customer for a transaction over 5k?
what if it was in an office?
If a customer has an access card or visa on their profile, we must verify their pin.
5K: 3 points of auth
Cards/PIN> OTP>ID> KBQ
Office: 2 points of auth ( OTP>ID)
BWEB ALLOWED
-Print and Provide the Information Box (which is the cost of borrowing) and if applicable, the additional Aeroplan Privacy Disclosure
- If a mini-app or full application is required (not preapproved), we must also provide the Privacy Agreement. If customer is using My E-Sign, we must have them review and agree to the TD Electronic Disclosures and Signatures Consent.
-Verbally disclose: All interest rates, The date when interest accrues/grace period, All non-interest fees, Minimum Payment requirements
-If the customer's requested credit card is a TD Aeroplan Credit Card, you should also explain the additional privacy terms that are contained in the additional TD Aeroplan Privacy disclosure
-Disclose and ask: "Do you consent to us providing you with the [name of product] on the terms we have disclosed to you?"
What is CASL? What does this mean for branch colleagues? NO BWEB
Canada's Anti-Spam Legislation (CASL) requires most Canadian companies obtain consent prior to sending any marketing emails or emails of a promotional nature. All other emails that are sent to customers will need to include relevant contact information in their messages and provide an unsubscribe option to their customers. For more information review the CASL Landing Page. To support the legislation, Branch Banking employees are not to send emails directly to customers to promote or advertise TD products or services. This includes upselling or cross selling products or promoting other TD lines of business through email.
What are the ID requirements for Cashing a Federal Government Cheque? NO BWEB
The person presents to the Bank:
A) Two documents from a reliable source — one of which indicates the person’s name and address and the other the person’s name and date of birth OR
B) One piece of identification that is issued by the Government of Canada or the government of a province and that bears the person’s signature and photograph; OR
C) Any document from a reliable source that indicates the person’s name and date of birth, if the person’s identity is also confirmed by a customer in good standing with the member bank or by a natural person of good standing in the community where the point of service or branch is located.
If a note passer, take the note to the cash device and leave it face up on the cash device. Go to the closest colleague (buddy system), lightly squeeze their elbow and ask for an "underride". Once you are both at the cash machine, hit F12 Emergency dispense key, dispensing $200. Combine cash with the Decoy and/or Dyepac/GPS in a clear plastic bag & hand over the money to the robber the cash. To end the interaction, both colleagues are to step back, decisively walk away from the workstation and disengage eye contact. Immediately notify the BM or manager delegate once the robber has left the branch. As soon as the robber leaves, branch is to lock the doors and call 911/police immediately, IRC should be phoned after calling 911. Cx and staff to be separated and should document their account of what happened. If cx wants to leave, we just need to take their contact information.
What commitment have banks made with the federal government regarding types of accounts offered
Banks must offer a low-cost bank account to ensure banking is accessible to everyone – This is an FCAC requirement per the Federal Government. Our account is called the 'TD Minimum Chequing Account' but BCP will be looking to confirm you refer to it as our 'low-cost account' offered due to the federal government commitment. Low-cost bank accounts must follow established guidelines, including: • Unlimited deposits • The use of a debit card • The ability to write cheques • At least 12 debit transactions per month, including at least 2 in-branch transactions where available • Low monthly fee • Monthly statements • Ability to set up pre-authorized payments • Free cheque image return or online cheque image viewing • Provided free of charge to: Youth, Students, Guaranteed Income Supplement (GIS) recipients, and Registered Disability Savings Plan (RDSP) beneficiaries
When selling a Non-Registered Term Deposit/GIC (non-market growth GIC) OR a registered Term Deposit/GIC (non market growth GIC) what must you disclose verbally and provide?
For Market Growth GICs:
Obtain customer's signature on all required forms and provide a copy to the customer
A customer requests to unsubscribe from receiving email (electronic messages)/ wants to stop receiving email, what do you do?
You need to modify the customer electronic communication preferences immediately using the Enterprise Permission Centre (EPC) tool. Be prepared to describe where you find the EPC tool on the Bweb or C3 preferences
Access to Funds Regulations - When can you refuse access to the first $100 of a cheque? NO BWEB
We can refuse access to the $100 in the following circumstances:
1. An account that has been open for less than 90 days
2. The cheque is double-endorsed
3. The cheque is stale-dated
4. Cheques that are not issued in Canadian dollars
5. Cheques that are drawn on an institution outside of Canada
6. Where you have reasonable grounds to believe that the cheque is fraudulent
If we refuse to provide $100 for any of these reasons, we must provide the customer with a Letter of Refusal.
What is access to basic banking?
Access to Basic Banking Services Regulations is Federal consumer protection legislation that specifies the types of identification FIs are required to accept from individuals that cannot meet the standard AML Identification Guidelines
TD is prohibited from entering a relationship or engaging in business with what types of business customers?
Shell banks, internet or online gambling organizations, and unlicensed marijuana dispensaries and producers, head shops, compassion clubs, vapor lounges, sanctioned entities and virtual/digital currency exchanges
RSC>Enhanced Due Diligence