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.
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?
07/14/2024
If I am refinancing a primary residence, do I need to include last year's insurance on the loan estimate and closing disclosure as a POC fee? Or can I just leave it off because insurance and taxes are accounted for on my Initial Escrow Disclosure?
05/14/2023
My bank made changes to language in the fee schedule and depository disclosures, pertaining to return items and non sufficient funds representments and statement language. Is there any reason the bank needs to notify the customer of these changes?
04/16/2023
We have a very small subsidiary bank whose contract with its core systemes provider is not being renewed. The bank obviously needs a temporary core system until they close a new contract with another provider.
One proposed solution is to onboard the small bank's 100 or so customers onto our core. We would manually process the small bank's transaction files from imported data, which our IT teams are handling. Bottom line, the small bank will retain its ABA#, but their debit cards will have to be reissued by us, the larger bank, and during the transition the cards will bear our name.
My concern lies in disclosures and compliance. What disclosures do we as the larger, "host" bank need to provide to the smaller bank's customers while their accounts are serviced by us, on our system? The smaller bank is a digital-only bank.
12/18/2022
Are there any specific delivery requirements for the FCRA Notice to Home Loan Applicant? For instance, does it suffice to make the Notice available through an application portal and not specifically email or mail the notice to the applicant?
If it's OK to simply make the Notice available through an application portal, do we need to at least send a communication (i.e., email) to the applicant telling them that a regulatory disclosure is available for their viewing within the portal?
05/01/2022
How can I add someone to a deposit account? Is there a specific procedure for the signature cards or disclosures if they're even needed?
07/18/2021
How do banks track disclosures?
01/10/2021
Our FI is planning on using Promontory to offer broker deposits to consumers.
I have thought that Reg DD, section 1030.4 thru 1030.6 (Account
Disclosures) apply, however the Agreement and periodic statement don't specifically
address by Reg DD the required elements. For example, their Agreement states
accrued interest will be credited "at least once each month" vs. a specific
frequency, and it does not reference if accrued interest will be paid or not
paid if the account is closed, and refers to the APYE as "Statement Period
Yield".
We have just received communication from the vendor and they are telling us
that "A Relationship Institution is a “deposit broker” for purposes of
TISA and, as such, is subject only to the advertisement provisions of Reg
DD." But they don't even spell out at least once Annual Percentage Yield.
Is our FI required to meet all the requirements of Reg DD as if the consumer
were opening one or our MMAs?
05/10/2020
Would escrow estimates be reflected on the LE/CD on a junior mortgage if those are being covered by the first?