Question of the Week

  • QUESTION: Does the bank bribery act require the bank to have a policy?

    ANSWER:

    The Bank Bribery Act is codified under United States Code 18 USC 215.

    The Bank Bribery Act itself does not require a specific policy. However, the banking agencies encourage banks to develop a code of conduct policy that addresses the requirements of the bank bribery act. Specifically, the policy should include what is considered a thing of value under the Act, and what is an exception to the Act – e.g., a lunch based on obvious personal or family relationships; a benefit that also is available to the general public; something provided with no expectation of reciprocation. The code of conduct should also include what the bank should do in the event of bribery. Reference: FDIC: Guidelines for Compliance with Federal Bank Bribery Law, 5000 Statement of Policy.

    The Bank Bribery Amendments Act of 1985 (Pub. L. 99--370, Aug. 4, 1985) amends the federal bank bribery law, 18 U.S.C. 215

                                                    


Question of the Week Archive

  • QUESTION: Is there a notice that must be provided on a website in reference to information collection for children as part of COPPA?

  • QUESTION: A credit card customer wants a second card for his son. The son, who is 18, will be able to use the card to make purchases. Does the bank need to perform an assessment of his ability to repay?

  • QUESTION:Recently, an advertisement went out with a rate that was incorrect. Does the bank have to honor the rate?

  • QUESTION:The bank recently filed a SAR, FinCEN has requested supporting documentation, doesn’t the Right to financial privacy act say that any record needs a subpoena to get the records?

  • QUESTION:For purposes of homeowners protection act, what does “good payment history” mean?

  • QUESTION:Will the Beneficial Ownership Rule Require Updates to the USA Patriot Act Notice?

  • QUESTION: If a borrower is not escrowing for taxes and insurance, do the monthly amounts for these items have to be disclosed on the Loan Estimate?

  • QUESTION: For a business application for credit, may the bank assume an application is for joint credit if the financial statement lists jointly held property by the husband and wife is signed by both spouses?

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

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

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