CTRs for Multiple Accounts with Same Ownership
Question: Hello, Heather! I was hoping you could help me with a question regarding a CTR filing. We had a member come in and withdraw cash from his business account that he owns. Then in a separate transaction he withdrew cash from his personal account. The purpose of both transactions are the same, and the […]
Expelling Members Who Have Caused a Loss
Question: Good Morning, Heather. We are a federal credit union. In the past, whenever a member has caused a loss to the credit union, we have charged off their loans and closed their account no longer allowing them to be a member of the CU unless they pay us back in full. We have never […]
Advertising Certificate Rates on Outdoor Signs
Question: Hi Heather. Our credit union is going to offer a limited time certificate promotion. The car wash next door has a reader board that we have used in the past for marketing, but we’ve never advertised rates. If we are going to offer a 12 month certificate at 5.25% with an APY of 5.27%, […]
Do I Need to Fill-in Every Field on a SAR?
Question: Hi Heather,Do you have a trick for remembering how to complete the “Selling Location” or “Paying Location” and the suspects role “Purchaser/Sender” or Payee/Receiver” fields on the FinCEN SAR form? I always trip myself up for cash structuring SARs. Answer: See Q&A #18 on FinCEN’s SAR FAQs: 18. How do we complete Item 56/68 […]
Let’s get back in the habit of breaking bread together.
When I’m out and about among our most excellent Utah credit unions, I frequently hear from the old-timers that, “We used to get together a lot. It was great. You knew everyone. You knew what was going on.” That’s why, at the Association, we’re going to start up a new series of round tables—to help […]
Delaying Outgoing Wires
Question: Hi Heather. I remember hearing that we could delay sending an outgoing wire for up to 15 days if we notify the beneficiary, but I can’t find where I read that before and want to review the rule again now. Does that sound familiar at all to you? Do you know where I can […]
What is Considered an Application for HMDA?
Question: Hi Heather, Quick question… We helped a member earlier this year with a reduction of his HELOC interest rate. An application was completed to ensure that he qualified for the reduction, but a new loan was not completed in our host system. Do we need to submit a HMDA filing for this application? Answer: […]
Advertising Certificate Rates
Question: Hey Heather. Our credit union is going to offer a limited time CD promo to bring some money in. We have an outside reader board that we have used in the past for marketing, but we’ve never advertised rates. I don’t want to be out of compliance, but if are going to offer a […]
What’s the Deal with Reg U?
Question: Hi Heather. I would like your opinion on Regulation U. The way I read it Reg U states any loan secured by stocks would have additional reporting requirements. But some others at my credit union think it means that the reporting is only required if stock is purchased and then used as collateral, but […]
