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Latest Compliance - Internal Controls Topics

Website Change Management

10/13/2019

We currently keep both electronic copies and paper copies of every change made on our website. This is time-consuming to maintain. How critical is it to keep hard copies of our work, and what questions should we be asking ourselves to potentially reduce or eliminate unnecessary paper trails?

Is a discount coupon a bonus?

09/01/2019

If we offer a discount coupon from a local business to a consumer opening a checking account, is that considered a bonus under Truth in Savings?

Callbacks for Online Auto-Enrollments?

09/01/2019

Are other banks performing callbacks for customers completing online auto-enrollments? If not, what are the controls for preventing fraud?

Advertising rates

08/18/2019

If we price HELOCs based on the applicant's credit score and loan to value ratio, so some borrowers get a lower rate than other borrowers, can we disclose the lower rate in our advertisement, or do we need to disclose both rates? Do we also need to specify the criteria for receiving the lower rate?

Lobby Advertising

08/11/2019

We often have lobby posters advertising products, services, benefits like trips on a discounted price and others things on display so staff can answer questions on these and to promote these items. Do they require the general FDIC advertising statement.

Can we offer a prize to everyone, for charity?

07/14/2019

We have a “spin the wheel” promotion. To spin, a customer must donate $1 that the bank donates to a charity. All the prize amounts on the wheel are more than $1 therefore all customers will get more than they donate. The amount won is then sent to the customer via our e-wallet app. We set a certain number of spins and it is done on a first-come-first-served basis.

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Check presentment, UCC, Mobile Banking, Check 21

02/18/2024

We have a business customer who had an employee negotiate their payroll checks a second time. This employee deposited their payroll checks through a mobile channel with their bank over a year ago and then deposited them again. They cleared our customers account because our duplicate detection only goes back a year. Our customer did not reconcile or review his accounts to notice the duplicate payments and wants to hold the bank responsible. They total about $11k. We already tried returning the checks for duplicate and as expected, they were returned for "Late Return". I am looking for any input as to how we can recoup the funds? The bank of first deposit (PNC) did take in stale dated checks as well as having their customer not adhere to mobile banking terms. Any input would be appreciated.

Correctly stating APYs over the phone

02/11/2024

When orally quoting a deposit rates over the phone, if the APY is 3.00%, does the the employee need to state the APY as 3.00% or can they say the APY as 3%? Likewise if the APY was 3.50% do they need to say the APY is 3.50% or can they say the APY is 3.5%?

Conductor Information for Aggregate CTRs

01/28/2024

We have a business customer whose deposit runners are refusing to provide their information for us to collect as conductors of cash transactions. These are typically smaller transactions, but we require a conductors information on all cash transactions over $1,000 for aggregation reporting purposes. They previously banked at a larger regional bank which did not require these runners to provide identifying information. Are we OK to make an exception for this business client unless it is a CTR reportable transaction?

Using a EIN on a personal account

01/28/2024

We have a customer that is an agent for one of the local insurance companies. She wants to open an account in her name only using the insurance company EIN, can we do that?

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