Financial institutions routinely open deposit accounts for consumers and businesses and the rules for providing account disclosures, deposit agreements, and signature cards are well established. However, the legal and compliance issues involved with closing accounts are often more complicated. Why? Because there are situations ranging from accountholder death, suspected fraud or money laundering, disputes between account owners, and requests to levy funds. This session will address two areas. First will be the challenges of closing or changing consumer accounts. Second will be specific complexities regarding various ownership categories of business deposit accounts.
- Consumer account fundamentals
- Joint accountholders – who has authority to change or close an account?
- Best practices for changing signers and signature card
- When an accountholder dies – notices and handling checks and U.S. Treasury check items
- BSA issues
- Closing an account for failing to provide required CIP documentation
- Closing an account if suspicious activity is detected
- Best practices for closing consumer and business accounts and related BSA exam procedures
- Business account essentials, including the four typical ownership categories and common challenges
- CIP rules, including beneficial ownership
- Basic requirements to open, change, and close accounts for sole proprietors, partnerships, LLCs, and corporations
- Death of a business owner
- TAKE-AWAY TOOLKIT
- Account owner/authorized signer information worksheet
- New account checklist
- Checklist for CIP acceptable identification
- Authorization to close account form and checklist
- Death notification form for consumer accounts and procedures
- Federal garnishment notice form
- Account closure form letter
- Employee training log
- Interactive quiz
WHO SHOULD ATTEND?
This informative session is designed for new account representatives, service representatives, branch managers, assistant branch managers, branch administration, deposit operations, BSA CIP staff, and anyone who works with new accounts.
SPEAKER: Susan Costonis, Compliance Consulting and Training for Financial Institutions
Susan Costonis is a compliance consultant and trainer. She specializes in compliance management along with deposit and lending regulatory training. Most of her 35-year career was spent as a banker in several areas including lending, loan administration, electronic banking, and compliance risk management.
Susan has successfully managed compliance programs and exams for institutions that ranged from a community bank to large multi-state bank holding companies. She has been a compliance officer for institutions supervised by the OCC, FDIC, and Federal Reserve. Susan has been a Certified Regulatory Compliance Manager since 1998, completed the ABA Graduate Compliance School, and graduated from the University of Akron and the Graduate Banking School of the University of Colorado. She regularly presents to financial institution audiences in several states and “translates” complex regulations into simple concepts by using humor and real-life examples.