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Compliance Companion®
Standard Procedures Manuals (SPM)
 

General Banking Operations July 2022


Part One of SPM #9 details the requirements for obtaining Taxpayer Identification Numbers, tax information reporting (1099-INT, 1099-MISC, 1099-OID, 1098s and lots more), the four different types of backup withholding, the Foreign Account Tax Compliance Act (FATCA) and FATCA regulations, and IRS penalty assessments. Copies of many of these IRS forms are included as an appendix to the Manual.

Part Two discusses a wide variety of Operations Topics, including how to handle accounts and safe deposit boxes upon the death of a customer, bankruptcy of a depositor, powers of attorney, California’s unclaimed property laws, safe deposit box and safekeeping operations, contests and sweepstakes, operations record retention issues (including a table listing common operations records and their required or recommended retention periods), automated overdraft program requirements and regulatory guidance, and California’s laws governing notaries public.

Part Three of the Manual addresses the important topic of Vendor Management, including a discussion of recent regulatory developments, key elements of a vendor management program, categorizing vendor relationships, conducting a risk assessment of the outsourcing decision, conducting due diligence on potential vendors, reviewing vendor contracts, and the ongoing monitoring of vendors. Several checklists are provided, including one for categorizing vendor relationships, another to assist in conducting an outsourcing risk assessment, as well as three others – one to guide a financial institution in conducting due diligence regarding a vendor, a second for reviewing vendor contracts and a third for conducting ongoing monitoring of vendors.

Part Four focuses on Branch Activities and related issues, such as establishing, closing or relocating a branch, notice of branch closings or reduced hours, the federal and California interstate banking and branching laws, and courier service operations.

The Manual has 496 pages of text and 117 pages of appendixes

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Compliance Companion

Compliance Companion® is a one-stop regulatory compliance resource for financial institutions. This online compilation of 19 industry-leading compliance manuals, including this SPM #9, General Banking Operations, takes the legalese out of federal and California laws and regulations, making it easier to understand and keep up with ongoing compliance developments.

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SPM 9
* Janet Bonnefin is retired from the practice of law with the firm.
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