Most Popular Compliance Content
Next Day - Same Day Availability
10/27/2024
We were recently audited and it was noted that because a customer can immediately withdraw funds from a deposit made that same day, that we should be disclosing as a same day availability bank. instead of next day availability. What is your opinion and how do you recommend wording the change on policy, notices, and disclosures? It seems most examples I find are all next day examples.
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."
Unauthorized Authorized Debits
09/29/2024
If a customer authorizes someone to use their card and gives them the PIN for a specific transaction, and that someone uses the card for additional transactions that were not authorized by the customer, is their any negligence by the customer for giving the card and PIN for the first authorized transaction? What are the requirements according to Reg E ?