Latest Compliance - Closed/Closing Accounts Topics

Donating Small Balances to Close

07/16/2023

Are depositors allowed to have the bank give away their small deposit balances tocharity? These would be deposits less than $1.00 and we'd allow them to direct this in writing or over the phone that they want the balance given to charity? As an example say the customer calls in to inquire on their balance and we tell them it is $0.12. They say "its ok, you can keep it." What if the account goes all the way to its escheatment date and a letter is sent and the customer again says "just keep the $0.12" because they are not interested in getting or cashing a check for that. Is such thing as a goodwill GL account allowed where these funds could be placed and donated to a charity? The funds would paid to a charity periodically or when a certain amount is reached in the account.. Is there any regulation addressing this?

Right to Re-consideration When Closing Acct.

09/27/2020

When sending a letter to close a member's accounts due to multiple fraud incidents, are we required to include verbiage relating to their right to re-consideration?

NCUA Regulation: Closing Out Members Relationship

09/22/2019

The NCUA has a regulation that will not allow a federal Credit Union to close out a member's relationship without being approved by the NCUA Board. However, the FFIEC manual allows for an institution to close out a member due to multiple SARs. Does the FFIEC Regulation supersede the NCUA regulation that requires approval before closing out a relationship?

Closing Accts. Due to AML, Legal or Adverse Media

11/04/2018

Was wondering if bankers can provide examples of what is allowed to be provided to their customers when they close accounts due to AML, Legal or Adverse Media concerns.

Definition of Reasonable Notice (Closing Accounts)

04/29/2018

How would you define reasonable notice used in the following terms and conditions disclosure? We may also close this account at any time upon reasonable notice to you and tender of the account balance personally or by mail. Reasonable notice depends on the circumstances, and in some cases such as when we cannot verify your identity or we suspect fraud, it might be reasonable for us to give you notice after the change or account closure becomes effective.

Correct issue date for the CloD

05/15/2016

If I send the CloD three days prior to closing, on the date of closing should the closing disclosure be dated the day of closing (issue date)?

Closing Account Due to Kiting

11/15/2015

We have a customer who we suspect is kiting. We are considering closing the account and writing the customer a letter stating that the account is being closed. Our question is what can say to the customer to explain why we are closing the account?

Cash to Close Changing from LE to CloD

11/08/2015

Are there set rules on the Cash to Close changing from the LE to the CloD? For example, borrower requests a cash out refinance. The LE discloses in the Cash to Close section that they will be receiving $50,000. We find out prior to closing they want to pay off a loan and receive the leftover money at closing. So the money to the borrower has drastically been reduced. Are the changes in cash to close regulated by certain guidelines?

Fair Credit Reporting Act Q&A

12/01/2004

What Is an Electronic Document? (Part II)

12/01/2000