07/11/2011
We are having the following Anniversary Special for one of our Branches. "Open a new "Totally Free Checking Account" (non interest bearing) with a minimum deposit of $100, direct deposit of paycheck and free debit card and we will give you a $25 gift card." Would the $25 gift card be reported as a 1099 Int. or 1099 misc? Why?
02/14/2011
On ILUTMA accounts, can the custodian have their paycheck direct deposited into the account?
07/05/2010
We have a customer who owns a business that is listed as a sole proprietorship with its own EIN. A man and wife own this business. They have several direct deposit accounts with us, one of them being a personal money market account. The only transactions that seem to go to the account are ACH credits for the business. These ACHs go on daily, with sometimes large amounts. I guess what I am wondering if this is OK. Shouldn't the ACH for the business be going to the business account?
05/05/2008
Our bank would like to pay $100 to every customer who opens a checking account and signs up for direct deposit. The incentive would be paid to the account upon confirmation of the service, which could be 30-60 days from account opening. In looking at the requirements of 217.101(b), I'm concerned that an examiner could argue that duration and minimum to open an account is a factor in the promotion. It goes without saying that an account would have to be established to hold the funds and I understand that direct deposit is an ancillary service. At the same time, the whole objective of the promotion is to get new customers and new accounts. Is this promotion risky from a compliance standpoint? Should we consider this non-employee compensation for IRS reporting purposes?
11/12/2007
I have a very technical GLBA question. It is my understanding that if all employees of the bank are required to have deposit accounts then they are also considered a customer under GLBA. If there happened to be a breach of employee nonpublic information through the HR department, say the payroll vendor was compromised and all employees' social security numbers were released, would this not be considered a breach under GLBA and notification required to the affected customers (employees) along with notice to our regulators? Is it possible since the breach occurred through HR department and was of employees' nonpublic information that it is not defined as a breach under GLBA?
11/05/2007
Are we required to send out a yearly savings statement? We know we have to send the monthly statements that have electronic items, but how about the rest?
10/22/2007
We are a new bank in formation in Oregon. Is there a maximum dollar amount that can used as a giveaway before a 1099 is necessary to be mailed to the customer?
02/12/2007
I am the Electronic Banking Specialist for [Bank Name Withheld]. We are having a debate among ourselves and our Legal Department regarding whether or not check imaging is covered by Reg E. One opinion has to do with whether the check image is truncated or not; another has to do with the intent for imaging, whether as a tool for the merchant to recover funds on a returned item, or as a bank tool to pacify clients who want their checks back. I would appreciate any input that you might offer as you have a more industry-wide view available, as well as experience in compliance and Reg E issues.
07/03/2006
If the Bank offers an interest-bearing checking account with perks such as: 1) sign up for direct deposit and the Bank will add $50 to your account after your first direct deposit, or 2) pay a bill online and the Bank will add $50 to your account after your first bill payment transaction - are these perks considered bonuses that need to be disclosed under Reg DD?
07/03/2006
If the Bank offers an interest-bearing checking account with perks such as: 1) sign up for direct deposit and the Bank will add $50 to your account after your first direct deposit, or 2) pay a bill online and the Bank will add $50 to your account after your first bill payment transaction - are these perks considered bonuses that need to be disclosed under Reg DD?