04/06/2025
Should we bring in compliance to assist when new or modified products or services are launched? If you do, should we have them come in early on or wait until the end or near the very end to "clean up" mistakes that were made?
03/30/2025
Does a Disclaimer of Oral Agreements requirement apply to consumer revolving line of credit loans? I know if the loan amount is over $50K you must give this notice; however, my vendor's loan origination system is not prompting this document. I believe it doesn't apply for a consumer open end credit loan.
03/30/2025
We have a customer who gave her grandson (who is not on her account) permission to put her debit card on the grandson's Cash App account. There have been transfers from our customer's account by debit card, to the Cash App account that is in the grandson's name.
They claim the grandson's phone was stolen and that the transfers were made by the person who stole the phone, not the grandson who was given authority to use the card. Where would the liability fall since the transfers went to an account in the name of a person who was given authority to use the debit card, but that person claims it was theft?
03/23/2025
Currently, when a customer comes into the bank and wants to add an agent/attorney-in-fact under a power of attorney to their accounts, we print a signature card for each account and have the principal (if able) and agent sign the signature card(s). Whether there is one account or 20. However, we are talking about possibly using one signature card for all accounts. Can we just list each of the different account numbers on one signature card and use the one signature card for allaccounts?
03/16/2025
Have you ever been standing on the side of the street waiting for a parade to start?
03/09/2025
We have a legitimate business need/permissible purpose to pull ChexSystems reports on those looking to open a consumer account. We know we do not need to get a consumer's permission to do so if they are asking to open an account in their names.
I was wondering if it works with business accounts (signers on business accounts as well). And will there be an issue if we report to ChexSystems?
03/02/2025
When we (Bank B) send a UCC Breach Of Warranty Claim for missing endorsement to Bank A, how long does Bank B have to credit our customer for their missing endorsement claim? Assume the liability is on Bank A, due to missing endorsement and should reimburse Bank B in full. Does Bank B wait for full payment before reimbursement to customer or is there a UCC required timeframe for customer reimbursement?
03/02/2025
Under the new CRA Assessment Area rules, if a bank is utilizing the Allpoint+ ATM network that allows for networked ATM+ machines to accept cash deposits, would this be considered a deposit gathering ATM location? And, if the bank wanted to open an LPO in a new state (not contiguous to its existing state or retail branch locations) where these ATM+ deposit gathering machines are located, could the Assessment Area include this new LPO market to help their in/out ratio?
02/23/2025
We use ChexSystems for deposit accounts. We have a legitimate business need/permissible purpose to run Chex on those looking to open a consumer account. Do we need to be obtaining written permission from the consumer prior to running Chex?
02/23/2025
Do we need to retain old FinCEN 314(a) files? If so, for how long?