Most Popular Compliance Content
Reg Z- VISA Open Loop Card "Replacement"
06/02/2019
The bank has used "replacement" to replace a private label card with a VISA open loop card. Some of the cardholders have not activated their cards, some probably because they threw away the envelope without opening their mail. The bank is considering placing a block on the cards, pending activation from the customer so that the customer can still activate rather than reapply. The other option is to send a letter to activate the account within a stated time, otherwise the account will be closed. The consumer would need to apply again for a card. IMO, the second choice is a better customer experience in the absence of some foundational regulation to assert one position or the other.
POA on Behalf of Legal Entity Open Business Acct?
05/27/2019
I am seeking your advice regarding an account we are preparing to open for a legal entity which is represented by an individual given power of attorney. The potential customer is a business registered with the Secretary of State, making them a legal entity who has given power of authority to a person that is not affiliated to the business. This person has come to open a business account in the company's name. The directors are from India and according to their Articles of Incorporation show the business located locally. Our question is, can an individual who is given power of attorney on behalf of a legal entity open an account for the business?
Placing ATM in Mall Location (No Branch in State)
05/26/2019
We have an opportunity to place one of our ATMs at a Mall location in Nebraska. Currently we do not have any branch locations in Nebraska. I was trying to find any information on whether or not that is acceptable. I don’t know if by regulatory prohibitions we are unable to place an ATM in Nebraska without a branch in Nebraska? I don’t know if limited service branch makes any differences either but I thought I would ask if it is a possibility. If you have any guidance on where I could find information about this topic I would appreciate it.
ATM Deposit Claim-Investigation Beyond 10 Days
05/26/2019
If a client makes a claim that the ATM did not deposit either cash or a check in the correct amount, however does not recall the amount of the cash or check, what should our bank do if the investigation goes beyond 10 business days when provisional credit would be owed?
Lending to MRBs
05/26/2019
Would HR 1595 provide protection when lending to MRBs?