06/04/2001
Is it permissible for a National Bank to offer a time-deposit promotion where customers opening that time-deposit would be entered into a drawing with the winner receiving additional (double) interest on their deposit? I have referenced Title 12, Chapter 2, Sec. 25a of the U.S.C., however, I am having difficulty interpreting the Code's definition of a "lottery."
05/07/2001
We received an endorsement forgery on an item dated in September of 2000. We truncate our checks. Can we still send an imaged copy of the check for collection to the depository bank and collect it after this much time?
03/05/2001
Please give some feedback on the following: Would regulators find this a violation to Reg. D? For very good business customers, a bank wants to have a savings account and a zero balance checking account. Monday through Thursday, all checks that pay on the checking account create an approved overdraft. On Friday night enough money is transferred from the savings to cover the overdraft. End result is checking starts out the week at zero and funds are only swept from savings once per week or four (maximum five) times per month, within the reg. D limit.
02/05/2001
What types of new scams are you seeing these days? Any we should be on the lookout for?
02/05/2001
I have heard that requiring a customer to write their account number on the back of a check that they are depositing to their acct may be in violation of RTFP because the check will end up in the statement of the individual who issued the check. Can you please shed light on this issue. This practice has been our standard policy for years.
02/05/2001
What is the progress of the proposal to change the limit of MMDA transfers for business accounts to 24 per month?
01/15/2001
We frequently have customers who wait 6 months to report forgeries. Our procedure has been to return the item at that time to the depositary bank. (We normally give the customer a refund) It is my understanding that we must return items according to Reg. CC, and this is much too late. Please tell me what we should be doing when this happens? I am new to compliance, but this does not seem like the correct way to handle forgeries. Our deposit agreement states that the customer should examine their statement within 30 days. I know that the customer has one year to report a forgery and three years to report a forged endorsement.
01/01/2001
by Barbara E. Hurst, Editor
It's the beginning of a brand new year and I'm going to take time out to pat a few of you on the back.
Here's a toast to:
12/01/2000
Compliance is full of "thou shalt's" and "thou shalt not's". This kind of command may be useful on stone tablets, but it doesn't prove to be the strongest motivator for employees.
05/01/2000