01/31/2011
We are a State Bank. Do our loan officers and assistants need to be registered in Texas? I'm getting conflicting information from different sources.
11/01/2010
It was my understanding that Rhode Island had a different timeframe for Reg. E - provisional credit. Although provisional credit is to be given within ten business days, RI stated that it must be issued within five business days. Am I correct?
10/18/2010
When we have a customer who exceeds the transaction limitations on a savings account due to online transfers, we restrict him from online banking. If he also has a sweep set up for overdraft protection, we do not remove the sweep, since this is not what put him over the transaction limit. Is this a violation of the Reg? Should we restrict him from online banking as well as remove the overdraft protection sweep?
08/09/2010
Relative to Reg D, the Federal Reserve Bank is currently paying interest on excess balances of eligible institutions. Is the payment of interest a permanent situation or does it have a sunset clause?
06/21/2010
I read a QandA recently that said if a bank is not required to post its credit card agreement on the federal site (fewer than 10,000 credit card accounts), it is not required to post the agreement on its own site. I do not read the regulation the same way, and I contacted ABA for clarification. 226.58(c) requires issuers banks to post the agreements on their own site in all cases, if the bank has a web site. Only the requirement to post with the federal is exempt under the fewer than 10,000 accounts as we read it. Please comment.
06/21/2010
We had a check returned to us as fraudulent. I was told by our Compliance Officer that we could have sent the check back to the paying back as "received in an untimely manner", and therefore could have recouped our funds, since the customer had already made a withdrawal for the entire amount of the check. She said that this was a new rule in addition to the new Reg CC rule. Is she correct? Can we return a check back to the paying bank if we determine it was not sent in a timely manner?
05/03/2010
Is an Early Truth in Lending disclosure required on an owner occupied one-to-four family purchase that includes over twenty-five acres of property?
04/19/2010
In the new REG Z guidelines, it states that credit card issuers must post credit card agreements on their web sites and submit those agreements to the Federal Reserve Board to be posted on its website. It then states that card issuers with less than 10,000 credit card accounts and accounts not offered to the general public are excluded from this requirement. We have less than 10,000 accounts, but are getting hung up on what is meant by accounts are not offered to the general public. We are still unsure whether we need to post these agreements on our website or not.
03/22/2010
Under the exception hold portion of Reg CC for New Account holds, what is the availability for cashier's checks, certified checks, teller checks, U.S. Treasury, state/local government, Federal Reserve and Federal Home Loan banks?
03/22/2010
Under new RESPA regs, is it ok to give a preapproval for a home loan with a property to be determined (TBD)?