When the Bank
receives a subpoena or other legal process requiring it to provide any and all
documentation related to an account, should it also provide copies of any SARs
filed?
The Bank would like
to open deposit accounts for a new municipal customer. Typically, when an
account is opened for a business customer, the Bank will collect Customer Identification
Program (“CIP”) information on the account signers in addition to the customer
because this helps identify the signer if they contact the Bank regarding the
account. Municipal customers tend to push back against this requirement and may
be only willing to provide limited information regarding account signers. What
does the law require and what is the best practice in this situation?
The Bank has purchased a participation interest in a loan secured
by a property in a special flood hazard area. The flood policy for such loan
does not show a flood zone. Will the examiners find that the policy is
sufficient proof of flood insurance coverage for the loan participation?