Most Popular Compliance Content
P2P Claim, No Agreement with Vendor
03/19/2023
I have a Reg E Section 1005.14(a) question. If a consumer is disputing a charge that originated as an ACH from a P2P or other fintech and we do not have an agreement with the P2P or other fintech, can we as a financial institution direct the consumer to file their dispute with the P2P? Aren't they subject to Reg E Section 1005.14(a)?
How can I gain a full picture of customer activity?
03/19/2023
How can I gain a full picture of customer activity?
Are bank statements required?
03/12/2023
I am looking for clarification on deposit account statements that must be provided for checking or savings account activity, both consumer and business. Reg DD does not require a periodic statement for consumer, but Reg E does, monthly if there is Reg E activity and quarterly if not. What about business accounts since neither Reg pertains to those? If not a requirement, is it a best practice?
Seeking Expedited Fraud Dispute Form
03/12/2023
I attended a great training webinar presented by BOL Guru Brian Crow on Mastercard vs Reg E rules. During the presentation he mentioned three Mastercard chargeback forms the bank could use in lieu of a signed cardholder document. Our operations department located two of the three. My question is, to inquire about the document form number for the "Expedited Fraud Dispute Form".
When to do CDD on loan app
03/12/2023
For loans that take months from application to closing, at what point would you recommend collecting updated Customer Due Diligence? My initial thought is that as long as the loan had not closed, we can rely on the information from the previous 90 days, but would want to verify/update after that period, and I am having difficulty finding guidance on specific timing.