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SARs and Legal Process
Issue/Inquiry
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?
CIP and Signers for Municipal Accounts
Issue/Inquiry
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 Flood Rules and Loan Participations
Issue/Inquiry
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?
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