06/01/2004
In Advisory Letter 2004-8, the OCC provides banks with a summary of requirements under the SCRA (Servicemembers Civil Relief Act) which became law on December 19, 2003 and modifies and replaces the
05/03/2004
Is waiving service charges for someone on board of directors a violation of Reg O?
04/19/2004
I'm in the process of completing an audit of the Fair Housing Act for a national bank. The OCC requires that "each bank shall attempt to obtain all of the information below." It then goes on to require a considerable amount of information in excess of the traditional government monitoring information (race, ethnicity, sex, marital status, and age). Is all of this information required to be on the application? Will the information (such as amount requested, interest rate requested, # of months to maturity, and proposed monthly payment) being in the loan file on some other document suffice? Also, does the fact that the application is partially completed suffice for compliance with the regulation for "attempting to obtain" the information?
04/05/2004
When advertising a stepped-rate CD, is a bank required to include all applicable simple interest rates along with the period each is effective (not more conspicuous than the APY)?For example, the bank offers a 60-month CD at 4.20% for the first 12 months, then 3.45% for 48 months, 3.65% APY. Can the Bank advertise the 4.20% for 12 months and the 3.65% APY without mention of the rate in effect for the remaining 48-months (3.45%)?
03/01/2004
When advertising a stepped-rate CD, is a bank required to include all applicable simple interest rates along with the period each is effective (not more conspicuous than the APY)? For example, the bank offers a 60-month CD at 4.20% for the first 12 months then 3.45% for 48 months, 3.65% APY. Can the Bank advertise the 4.20% for 12 months and the 3.65% APY without mention of the rate in effect for the remaining 48-months (3.45%)?
12/15/2003
When opening new accounts over the phone, do the APY and interest rate have to be disclosed or is it only necessary upon request? And when providing general information about an account, does the APY and interest rate have to be disclosed?
11/03/2003
My bank has finally rolled out a HELOC product and an openend personal credit line product. Now, I have officers that are pleased to have the product, as long as they can modify it to fit their needs (ie. CP vs program CP+1%; waive the $75 application fee; change term from five years to two years). It is my understanding that these consumer products have to be offered to all with the same terms and conditions, but I need regulatory ammunition immediately to put a stop to the "customization" that is taking place. Help!
08/25/2003
We would like to offer a benefit to our employees by allowing 1.00% off published interest rates. Would this be violating any regulations? Any effect on executive officers and Reg O?
06/09/2003
What are the regulations regarding the maximum interest rate banks can charge on closedended loans secured by CDs? We charge 3% over the rate the CD is earning with a minimum rate of 6%. Is this permissible?
05/12/2003
Regarding Truth In Savings Disclosures for Certificates of Deposit with terms over one year. If a bank does not compound interest on CDs with terms over one year, pays simple interest, and allows the customer to add on the interest earned for the first year to the original amount, is it proper to mark the TISA disclosure as "CD not compounding and interest credited upon maturity of CD"?