Most Popular Compliance Content
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?
Lobby Advertising
07/09/2023
We often have lobby posters advertising products, services, benefits like trips on a discounted price and others things on display so staff can answer questions on these and to promote these items. Do they require the general FDIC advertising statement>
Reporting winners to the IRS
07/09/2023
We ran a contest and no prize was over $300. We didn’t need to collect non-public private information from the winners since the prizes were small, did we?
A bake sale by any other name…
07/09/2023
Every year we do a bake sale to raise funds for Breast Cancer Awareness/Local Hospital Foundation. Is this acceptable?
Advertising rates
07/02/2023
If we price HELOCs based on the applicant's credit score and loan to value ratio, so some borrowers get a lower rate than other borrowers, can we disclose the lower rate in our advertisement, or do we need to disclose both rates? Do we also need to specify the criteria for receiving the lower rate?