Most Popular Compliance Content
General Rules for Account Agreement Changes
05/05/2019
Our attorney posed a question to me that he received from a customer. He wants to know under what circumstance do we change our deposit disclosures? I told him when we have a regulatory change or a policy/product/service charge or other change. Also, I said if the change is adverse to the deposit customer we have to notify them in a certain number of days according the change requirement or regulatory requirement. If the change is to the customer's benefit, we may or may not do a mailing and just post it on the website, social media or on the their statement. Our attorney wants to know the general rules for account agreement changes, when to change them and where it appears regarding the adverse change or customer benefit change. Any thoughts?
Business Trust List Beneficiaries?
04/28/2019
Can a business trust list beneficiaries on the trust account? For example, another bank would like to set up a trust account with our bank and list their customers as the beneficiaries.
Adding to Time Acct. After Initial Funding
04/28/2019
Can we put a cap on how much may be added to a time account after the initial funding? For example, if a customer opens a time deposit with $5,000 and then wants to add $100,000, we would not allow that. Can we put a restriction in place that you could not add more to the account during the term than the original amount, so if the account was opened with $5,000 that they could not add more than an additional $5,000? Also can we allow an HSA CD to be a time account, or are there restrictions on this?
Counseling Reports for Excessive Overdrawn Accts.
04/28/2019
What are the requirements in relation to counseling reports for excessive overdrawn accounts and what regulation can I find that in? We already send notification out each time an account is overdrawn more than 6 times in a 12 month period. We also contact customers via phone and letters at 15, 30, and 45 days of being overdrawn. Are we required to mention "counseling?"
CTR for an ITF Account-Filing Guidance
04/28/2019
We need to do a CTR for an ITF account because the custodian came in and withdrew over $10K. For filing guidance we see examples of deposits, but not of withdrawals. Should the beneficiary of the trust be on the CTR assuming that funds withdrawn were for them? All we know is that the beneficiary walked out with the money. Also, should "ITF" be shown on the CTR anywhere?