Question of the Week

  • QUESTION: Can I still exempt a customer from CTR reporting that engages in both ineligible business and eligible non-listed business activity?

    ANSWER: To be eligible under the Phase II exemption, a non-listed business must not receive more than 50% of its revenue from an ineligible business activity. Ineligible business activities include but not limited to professional service firm (i.e. law , accounting, medicine), pawn shop, gaming, investment advisory services, real estate brokers, title insurance, marijuana related business, auto dealer,  boat dealer and any transportation related vessel. A rule of thumb is anything that rolls, floats or flies.


Question of the Week Archive

  • QUESTION: Where do I find rulemakings and a list regarding BSA 311 special measures?

  • QUESTION: What are the exemptions from the requirements to purchase flood insurance?

  • QUESTION: Would fair lending apply to third parties that accept applications for the bank?

  • QUESTION: How can consumer show consent to receive electronic disclosures, so the bank can communicate electronically with the consumer?

  • QUESTION: What are the requirements for covered financial institutions to collect beneficial ownership information?

  • QUESTION: When is a change in terms notice required under Regulation E?

  • QUESTION: When does the bank have to use a combined adverse action notice that contains both Regulation B and FCRA information?

  • QUESTION: Besides cities, towns, and counties, what other units of local government are political subdivisions for CRA purposes?

  • QUESTION: Where is advertising addressed in fair lending?

  • QUESTION: The Servicemembers Civil Relief Act Notice Disclosure from HUD expires on 12/31/2017. What do we do come January 1, 2018?

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