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Latest Compliance - Disclosures Topics

Reg Z TILA Disclosures Requirements for Fixed Loan

06/03/2013

Are any TILA disclosures required when an open end HELOC has the option to fix portions of the line during the draw period? The fixed loan options are tied to the line and work like a credit card with fixed rate options.Where in Reg Z is this addressed?

Disclosures for Changing Payment Terms

05/06/2013

I want to change the payment terms (lower the payment amount) on a consumer car loan because the borrower made a large principle reduction. Rate, maturity date, and payment date will stay the same. I would also like to release unneeded collateral due to the significant decrease in the loan balance. What disclosures are required?

What Is Considered Close Proximity Reg E?

04/08/2013

If a customer opens a new account and is given Reg E disclosures at that time and later requests an ATM or debit card, do disclosures need to be provided again with the card even if they are the same as previously provided? What is considered close proximity?

Reg Z Disclosures- Overdraft Repayment Plan

03/25/2013

Regarding overdraft repayment plans: Reg Z disclosures will be triggered if the loan is payable by written agreement in more than 4 installments. So, as long as the written agreement says 4 or less payments, may the consumer make bi-weekly payments totalling 8 payments until paid in full and still be compliant without giving Reg Z disclosures?

Opt In/Opt Out Requirements for eStatements

03/25/2013

We are getting really to roll out eStatements. Where do I find information on who is required to sign an Opt In/Opt out agreement (Business or Personal Accounts)? When must the statement be available to view online? etc etc.

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Completing CTRs on a business account

08/18/2024

When filing a CTR on a business deposit, do you include everyone on the account like you would a personal CTR or just the actual conductor?

Records retention and canceled remittance transfer

08/18/2024

Regarding a cancellation request of a consumer foreign remittance transfer - are there any document retention requirements related to the canceled wire transfer request? Is the FI required to retain a copy of the wire transfer request form or any other documentation related to the transaction since it never occurred if canceled within the 30-minute window? Our bank has a log to record all canceled international wire transfer requests, but that is the only documentation.

Subpoena/summons investigations results and SAR filing

08/11/2024

Our BSA Officer manages our bank’s filing of Suspicious Activity Reports (SARs) with FinCEN. She has asked to include in our policy for managing summonses, subpoenas and similar legal documents a requirement that she be notified of any suspect activity that might be turned up in searches in response to those documents. Is that allowed?

Recognizing recurring and non-recurring debit card

08/11/2024

Can a merchant force a debit card transaction by claiming that the transaction is a recurring transaction event though it's not? For example, the customer opted out of overdraft service for ATM and one-time POS debit card transactions, but a merchant forced the transaction by claiming it's recurring.

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