Most Popular Compliance Content
Conditioning Overdrafts on Opt-in
01/07/2024
Reg E (12 CFR 1005.17(b)(2)) says we cannot condition the payment of checks and other transaction on the whether the consumer has opted into overdrafts via ATM and one-time debit card transactions. However, it does not clarify whether the opposite is allowed – meaning can you condition ATM and one-time debit card transactions on whether someone has opted into overdrafts via check and other transactions? I can't find any guidance on this question, so any advice is much appreciated.
Can we waive early withdrawal penalties on CDs?
01/07/2024
Can we waive early withdrawal penalties on CDs?
Stopping Preauthorized Payments
01/07/2024
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.
Where are Check Return Limits Specified
12/31/2023
Where in the regulations does it spell out the time limits and liabilities for banks regarding counterfeit checks, altered checks, forged endorsements, etc?
When to return stolen checks
12/31/2023
What is the time frame to return a check which was forged or fraudulently altered, i.e. stolen and washed?