Most Popular Compliance Content
Check presentment, UCC, Mobile Banking, Check 21
02/18/2024
We have a business customer who had an employee negotiate their payroll checks a second time. This employee deposited their payroll checks through a mobile channel with their bank over a year ago and then deposited them again. They cleared our customers account because our duplicate detection only goes back a year. Our customer did not reconcile or review his accounts to notice the duplicate payments and wants to hold the bank responsible. They total about $11k. We already tried returning the checks for duplicate and as expected, they were returned for "Late Return". I am looking for any input as to how we can recoup the funds? The bank of first deposit (PNC) did take in stale dated checks as well as having their customer not adhere to mobile banking terms. Any input would be appreciated.
Certificate of Deposit
02/18/2024
I am new to the compliance function so I apologize if this does not make sense. My question addresses Reg DD and a CD interest payment date vs. maturity date. Here is an example: a CD term is 6 months and interest is paid every 30 days. Since there are more/less than 30 days in some months the interest payment date does coincide with the maturity date, so there are generally a few days between these dates. I am unable to find anything in the TISA reg about this. How and when is interest paid in relation to the maturity of the CD?
CD Renewal Rate Disclosures
02/11/2024
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?
Correctly stating APYs over the phone
02/11/2024
When orally quoting a deposit rates over the phone, if the APY is 3.00%, does the the employee need to state the APY as 3.00% or can they say the APY as 3%? Likewise if the APY was 3.50% do they need to say the APY is 3.50% or can they say the APY is 3.5%?
What Annual Training is Required Per Regs?
02/11/2024
What are the mandatory (required) training courses for employees to take annually?