04/28/2014
For Reg. O compliance, is a Demand Clause required to be included in the Note for overdraft loans to executive officers?
02/03/2014
Can the bank exercise right of set off for overdrafts caused by debit card use?
06/24/2013
My question is about the fee summary at the end of a checking statement. The Total for this period column would be for that specific statement cycle. The Total Year-to-Date column is where my question comes. Assuming that an account had NSF/OD from 12/18/12 thru 12/28/2012 and the statement cycle was 12/18/2012-1/17/2013. The first statement printed in 2013; the Total Year-to Date field should be zero, correct; however the Total for this Period would include the fees for the entire statement cycle. From a compliance perspective, the Total Year-to-Date column would be missing any fees that happened between 12/18/2012-12/31/2012 correct?
04/01/2013
We are a small community bank that does not offer an overdraft program. We elected to opt out of the Reg E amendment effective July 1, 2010 and are paying one time debit card transactions that overdraw accounts without charging an NSF fee. Obviously we are losing income because of this. We are wondering if we could charge a reactivation fee on the debit cards that have overdrawn for the second time. Example: customer overdraws account with one time debit card transaction. We suspend the card. The customer deposits and we unsuspend. The customer does it again, we suspend, they deposit and we charge a reactivation fee to reactivate the card the second time. Is this ok? If not, can we charge an annual fee on debit cards?
01/14/2013
Is their any regulation that would make us out of compliance to have a age restricted account. We want to have a no fee checking account for 18-24 years old.
10/29/2012
We have a case-by-case hold policy at the bank where I work. We give a written hold notice to customers when we are placing a hold on their deposits. We have one customer who makes multiple deposits each week. Due to the history on the account, we place a hold on all check deposits into this account. The customer is aware of this. Are we permitted to forgo the written notice step of the case-by-case hold for this customer?
06/18/2012
Are board of directors and executive officers exempt from having Overdraft safeguard? What if they are listed in a non-owner relationship in a deposit account?
05/21/2012
If a director or executive officer is a custodian or power of attorney on an account of their child or wife, does that account need to be monitored under the Reg O overdrafts limitations applicable to executive officers and directors?
05/14/2012
Does Reg O cover depository accounts whereby I am making a proposal for the business depository services to a Director who owns his own business? Is it okay to waive the service charges for one year to allow time for all of the accounts to be moved and to determine the actual deposit activity once the accounts are at our bank? This is done for regular business customers from time to time when we are competing for the business.
05/07/2012
Our Bank is considering using a "Request to Reinstate VISA Debit card and Account Overdraft Agreement" for customers continually overdrafting their account with their Debit Card. What are some of the compliance issues we may face?