Steve H. Powell & Company

  • Contact
  • About us
  • Management
  • Services
    • Loan Review
    • Compliance
    • Due Diligence
    • ALLL Methodology
    • Strategic Planning
  • Newsletter
  • Blog
  • Contact
  • About us
  • Management
  • Services
    • Loan Review
    • Compliance
    • Due Diligence
    • ALLL Methodology
    • Strategic Planning
  • Newsletter
  • Blog

​

Cashing Checks for Non-Customers – BSA Compliance

6/29/2017

1 Comment

 
The Georgia Department of Banking and Finance recently released their May 2017 bulletin which contains a new interpretation on financial institutions’ responsibility when cashing checks for non-customers.  The DBF’s announcement does not appear to be based on any new rulemaking.   The bulletin states,

“Financial institutions are still responsible for the verification of a person’s identity when processing a transaction, such as cashing checks. The institution should verify the identity of the person receiving the proceeds and obtain and retain a record of the name and address, the type of identification reviewed, the number of the identification document (e.g., driver’s license), and the person’s taxpayer identification number (e.g., social security or employer identification number) or, if none, alien identification number or passport number and country of issuance. Verification of the identity of an individual who indicates that he or she is an alien or is not a resident of the United States may be made by passport, alien identification card, or other official document evidencing nationality or residence (e.g., a foreign driver’s license with identification of home address).”

This commentary would require many institutions to increase the documentation currently obtained for non-customer check cashing.  However, the bulletin states institutions should establish limits and utilize a risk-based approach to the category of checks the institution will accept.  Although acknowledging that certain checks pose less of a risk, it is unclear whether the bulletin’s identification procedures will be an agency expectation of all non-customer check cashing procedures or will be risk-based depending on the check cashing services offered by the bank. 

At this time, it is our recommendation that institutions consider implementing these verification procedures for non-customer check cashing for items other than on-us, payroll, or government checks.  Institutions may also want to consider applying the verification procedures when cashing on-us, payroll, or government checks above a determined dollar threshold. 


To read the DBF’s bulletin. Click here. 

1 Comment

    Past Articles

    All
    2017 DBF Final Rulemaking
    2017 TRID Final
    2017 Updated Guide For Servicing Rules
    2018 Compliance Updates
    April 2018 TRID Rule
    Beneficial Ownership Relief Extension
    Cashing Checks
    CFPB Annual Privacy Notice
    CFPB Prepaid Account Rule
    Commercial Real Estate
    CRA Lobby Notice
    CRE Concentrations
    Final Arbitration Rules
    FinCEN Finalizes Beneficial Ownership Relief
    HMDA Proposed Changes
    New HMDA Interpretive Rule
    Reg CC Reminder
    Regulation CC Final
    Restoration Of PTFA
    Rising Interest Rates Reg E
    SARs Data Fields
    SARs On Cyber Crime
    Second FAQs For Beneficial Ownership
    The Military Lending Act
    Visa Gross Negligence Change
    Visa & MasterCard Card Updater Services

    Archives

    February 2023
    January 2023
    December 2022
    November 2022
    October 2022
    September 2022
    August 2022
    July 2022
    June 2022
    May 2022
    April 2022
    March 2022
    February 2022
    January 2022
    July 2021
    May 2021
    February 2021
    January 2021
    October 2020
    August 2020
    May 2020
    April 2020
    March 2020
    February 2020
    January 2020
    December 2019
    November 2019
    March 2019
    January 2019
    September 2018
    August 2018
    June 2018
    May 2018
    April 2018
    February 2018
    January 2018
    October 2017
    August 2017
    July 2017
    June 2017
    March 2017
    February 2017
    October 2016
    September 2016
    August 2016
    June 2016

    RSS Feed

Powered by Create your own unique website with customizable templates.