Most Popular Compliance Content
Advertising rates
07/02/2023
If we price HELOCs based on the applicant's credit score and loan to value ratio, so some borrowers get a lower rate than other borrowers, can we disclose the lower rate in our advertisement, or do we need to disclose both rates? Do we also need to specify the criteria for receiving the lower rate?
Reimbursing Paid Fraudulent Checks
06/25/2023
Is a bank obliged to reimburse a consumer client for a fraudulent check paid out of their checking account? (We are in New Jersey.). Also, the client reported the fraudulent checks 10 months after statement cut which is deemed late according to our account agreement. I have not been able to locate a rule/code or law that makes us liable to a consumer for this.
Internal raffles matter
06/25/2023
Can we do an internal raffle (selling tickets for a chance to win a prize) to benefit a non-profit organization?
Complaints, Forgeries, and a Deceased Customer
06/25/2023
We currently have an individual stating that a forgery has been committed on a DBA account that was owned by his mother. The account had an authorized signer, who was added by the account owner. The account owner passed away in November 2022 and it is the Personal Representative stating that forgeries were completed by the authorized signer's wife. I have been investigating the statements and now the Personal Representative has filed a complaint with our regulator saying we are not responding to his claim. That is incorrect. We have reached out to the bank's legal counsel on the claim, but I'm looking for advice on handling the complaint with the regulator? The forgery claim investigation is ongoing.
High Risk? Anybody or Nobody?
06/18/2023
Who is high risk for BSA?