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?
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?
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?