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Latest Compliance - Disclosures Topics

ARM Programs-Rate and Payment Change Date

03/01/2020

Our bank would like to offer a 20/15, 25/15 and 30/15 loan where the interest rate is fixed for 15 years then changes one time for the remaining term. Everyone we've talked to says these are ARM loans. However, in our loan platform all ARM programs must have a subsequent rate and payment change date. Is anyone else offering these products? If so, how are they disclosing?

Reg E Type of Transfer/Type of Account

03/24/2019

Under Regulation E, section 1005.9(b), Banks are required to include the type of transfer and the type of account to or from which the transfer was made. The commentary doesn't specify how you disclose the type of account under this section (however, it does specify how to disclose this for terminal receipts under 9(a)). So, my question is, is it OK that our periodic statements just state "transfer from account XXXX" instead of specifying the account type or should it be stating transfer from checking/savings?

Considerations When Building TIS​ disclosures

03/11/2018

We are moving our accounts to a relationship style checking with service charge refunds with certain transactional behavior.(ACH, POS, eStatements,etc) What are some considerations we need to remember when building the TIS​ disclosures​?

Electronic Notice/Disclosure Through Mobile Alert

09/17/2017

We are looking into providing electronic NSF notices; OD first OD and current balance; loan payment reminders and past due reminders; CD interest payment due date; CD renewal-maturity date with current balance; CD Maturity-Maturity Date and Current balance; and loan balance notifications all through mobile alerts. This will be provided through our core and not through our online banking/mobile product.​ We are mainly focusing on providing the NSF and OD notices through mobile alerts at this time. I found on BOL your webinar “E-SIGN – Use it Write or Not at All” and wondered if this would apply or is there another webinar that would assist us to make sure we comply with our intention of these electronic notices and disclosures through mobile alerts?

Online Platform for IRA Contributions- Disclosure

09/17/2017

If an individual uses an online banking platform to make IRA contributions, must the platform display a disclosure that the deposit will be credited to current calendar year contribution? Is it required to allow the contribution to be designated for a specific year?

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Next Day - Same Day Availability

10/27/2024

We were recently audited and it was noted that because a customer can immediately withdraw funds from a deposit made that same day, that we should be disclosing as a same day availability bank. instead of next day availability. What is your opinion and how do you recommend wording the change on policy, notices, and disclosures? It seems most examples I find are all next day examples.

Stopping Preauthorized Payments

10/20/2024

We currently have outside counsel providing what I believe is inaccurate guidance. However, I'm struggling to find resources I can use to refute their regulatory interpretations. Specifically, this applies to a consumer's right to stop payment under 1005.10(c). Can you please advise how these requirements apply to: 1. Preauthorized transfers for loan payments (we are the lender/servicer) drawn on both external (we obtain debit authorization) and internal deposit accounts; and 2. Preauthorized bill payments both issued against the bank's/vendor's account and debited directly from the consumer's account. We hold the consumer's deposit account and offer the bill pay service.

'Member FDIC' in trust department ads

10/13/2024

Our bank has a trust department and they want to run an advertisement. Does "Member FDIC" need to be included in the ad? The ad will state something like, "We can help you with your Trust and Estate Planning."

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