Most Popular Compliance Content
Accounting Teams at Banks
02/20/2022
What are the basic duties of bank accounting teams?
Returning POS transfers
02/20/2022
Is there a possibility that POS transactions can be returned the same way ACH transactions are?
Periodic Statement Revisions Allowed?
02/20/2022
Our current periodic deposit account statements show all the required parts for compliance required at 1030.6(a). We show the APY Earned based on the General Formula from Appendix A-2.2.A. If we decide to remove only the “Interest Rate” reflected on all periodic deposit account statements going forward, could we be out of compliance with 1030.6(a)? Also, if we continue to leave the interest rate on the periodic statements, would it be an UDAAP issue, potentially causing confusion for consumers to see a different interest rate on periodic statements than what is on their TISA, due to fluctuations on deposits and debits?
Opt Out Early Deposit
02/13/2022
Our bank offers early access to direct deposit funds, up to two days early depending on the timing of the submission from the payer. The bank wants to add an Opt-Out option for customers who prefer not to receive direct deposits early. Could you please confirm there is not a operational or regulation reason why the bank cannot accept an Opt-Out request either verbally or in an email. We want to make the Opt-Out option easy for the customer without requiring a signed form. The bank plans to document the customers name and date of request in an account note.
Incentive payments and 1099s
02/13/2022
Our bank would like to give current customers $25 cash to refer a friend. We have been advised that those clients must then receive a 1099 at year end for the "gift." I've seen other banks do this successfully so are they all issuing a 1099?