Most Popular Compliance Content
Are All Private ATM Owners Equal
09/29/2024
I have read through several articles on private ATM owners and the enhanced due diligence on these; however, none seem to call out private ATM owners that do not have access to fill the ATM. Would these customers have the same expectations? Would it be necessary to tag these customers, obtain contracts/agreements and do yearly reviews of activity?
Batch processing vs. transaction level processing for deposits automation
09/22/2024
Why are financial institutions moving away from batch processing?
HSAs and Balance Transfers
09/15/2024
Are banks held accountable when customers transfer money from HSA accounts to personal accounts or LLC accounts?
CD Renewal Rate Disclosures
09/15/2024
I have a question about a CD special. The bank's rate sheet lists a 12-month CD as well as a 12-month CD Special that has a considerably higher interest rate/APY than the regular base CD. The bank also allows negotiation and will pay a higher rate to keep business. For the "special" and any other negotiated rate, the rate is only in effect for the initial term and at maturity will renew at the 12-month non-special rate. I'm looking at 1030.5; Comment 5(a)(1)-1 and I am thinking that advance notice would be required since the terms are changing upon the occurrence of an event (renewal). There is nothing on the TIS disclosing that the initial term is a promotional period and that the CD will renew at the lower non-special rate in effect. Am I thinking about this correctly?
Section 1071
09/15/2024
What is Section 1071 of the Dodd-Frank Act?