03/09/2009
How can a bank achieve assured compliance given the constrained information security budgets today?
03/02/2009
Under the new broker push-out rules Reg R guidelines, it looks like banks do not receive the exemption for IRAs on which they are named as a trustee. Our trust department IRA governing documents name our bank as trustee. It would appear then that we would not meet the requirements of the exemption. Is this the correct interpretation of the IRA and Employee Benefit Accounts exemption language or do we receive the exemption because the accounts are offered/managed in the trust department?
03/02/2009
If our institution charges an appraisal review fee and the review appraiser is an employee of the bank, is that charge considered a prepaid finance charge for Reg Z?
01/26/2009
What sort of controls and consequences can a Bank implement to set policy for employees who default on loans made through the employer?
01/05/2009
Does a cashier’s check for $10,000 have next day availability or does the large deposit exception take place?
12/15/2008
Is a marketing button for bankers to wear considered an indoor sign for compliance purposes? Do we really have to spell out APY, etc?
12/08/2008
Among credit risk, market risk and operational risk, developing a good operational risk management program seems to be the most challenging. Can't our existing compliance processes (e.g., AML, Red Flags, GLBA, etc.) contribute to operational risk management?
11/03/2008
We have an employee who obtained a $250,000 loan secured by a second trust deed on his residence and used the proceeds to purchase a new home. After the loan was made the employee was promoted and is now an executive officer of the bank. Do we have a potential Reg O violation? The credit does not fit within the established exemptions and is in excess of $100,000.
10/10/2008
08/11/2008
Can you please clarify the bank's responsibility and liability regarding Reg E compliance and MasterCard Zero liability related to business debit cards?