Question of the Week

  • QUESTION: Can a business savings account be exempt from CTR requirements?


    Phase II exemptions are applicable only to the extent of their transaction accounts. In 2000, FinCEN ruled that MMDAs are classified as transaction accounts for exemption purposes. An MMDA for purposes of this rule is any interest bearing account as described in 12 CFR 204.2(d)(2). Additional business accounts that do not qualify for exemption are CDs, credit cards, and loans. 

    Reference: 31 CFR 1020.315(e)(9); 12 CFR 204.2(d)(2).

Question of the Week Archive

  • QUESTION: May a prepaid card be set up without requiring customer identification verification?

  • QUESTION: Is a bank employee permitted to receive a referral fee under Regulation R?

  • QUESTION: When a fee change to the account is relevant under both Regulation DD and Regulation E, which timing should be used?

  • QUESTION: The bank has an arrangement with an insurance company to offer homeowner’s insurance to borrowers that have gotten a mortgage. Does the bank need to provide a privacy opt out notice regarding the insurance company or can the bank get consent?

  • QUESTION: Do SCRA foreclosure rules apply only to the service member`s primary residence, or do they apply to all loans secured by a mortgage on a residence? Does it matter if the loan is for business purposes?

  • QUESTION: Is someone who is named an executive officer in title only bound by the requirements of Regulation O?

  • QUESTION: Recently a customer’s relative wants to use a power of attorney for the customer citing a change in medical health. Is the bank permitted to use the customer’s medical records to assist in determining whether the POA is permitted?

  • QUESTION: Is the bank responsible for any NDIP sold by a broker through a networking relationship?

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