Most Popular Compliance Content
1026.53 Payment Allocation- Definition of Balance
06/02/2019
1026.53 - Payment Allocation reads pretty clear - payments in excess of minimum payment must be made to the balance with the highest APR and then descending until the payment is exhausted. But "balance" is not clearly defined. One could argue there could be two different balances. Cycle to date balances (in current cycle) or cycled balances (prior cycle) For example; suppose a card holders billing cycle is the 1st – 31st with a payment due date of the 21st. The account has the following balances that rolled over from prior cycles; $10,000 BT Promo at 0% $225 Purchase at 11.99% On the 21st the card holder makes their minimum payment of $25 which is applied to interest, fees and balances on the account in accordance with Regulation Z. On 23rd the card holder makes a $500 purchase at 11.99% and a $2000 cash advance at 12.99%. On the 28th the card holder makes an additional payment to the account of $3000. Should the additional (excess) $3000 payment be in the following order; $2000 to the cash advance balance at 12.99%. $700 the purchase balance at 11.99% $300 to the BT Promo at 0% or Do not apply any of the excess payment to the transactions that occurred in the same cycle. Alternatively, the payment is applied to the balance in the prior cycle: $200 to the purchase balance at 11.99% $2800 to the BT Promo balance at 0% and nothing to the cash advance balance What is correct?
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.
Fraud alert and error claim on debit card
06/02/2019
We have a consumer customer that received a fraud alert on his debit card for "Google Roblox" and he confirmed not his. It was hot carded and a new card was given to him. A week later another fraud alert was placed for "Google Supercell". He said ok to that transaction so card was released from warm status. A month later another fraud alert was placed for "Google Roblox" and he said fraud. After, a month he is claiming fraud on over 75 transaction on both Google Roblox and Supercell. Does he have charge back rights for both or just Roblox?
NSF Check for Collection-10 Day Rule
06/02/2019
We received a letter from another bank with a check for collection. It was returned to them as NSF and they would like us to collect on it. We are wondering if it is 10 business or calendar days that we as the bank needs to look?
Legality of CBD under New Farm Bill
06/02/2019
I was told the 2018 Farm Bill legalized CBD. Is that true?