Most Popular Compliance Content
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.
Special handling for National Security Letters
10/20/2024
Who should handle any National Security Letters that our bank might receive?
'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."
Are All Private ATM Owners Equal
09/29/2024
I have read through several articles on private ATM owners and the enhanced due diligence on these; however, none seem to call out private ATM owners that do not have access to fill the ATM. Would these customers have the same expectations? Would it be necessary to tag these customers, obtain contracts/agreements and do yearly reviews of activity?
Certificate of Deposit
09/29/2024
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?