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Latest Compliance - Investments Topics

Advertise for Affiliated Investment Company

06/30/2019

Is a bank permitted to advertise for an affiliated investment company on the bank's website, such as by offering a link to access the investment company services? If yes, what type of disclosure do we need to provide to the customer?

List of Services in Lobby-Omit Disclosures?

12/02/2018

Marketing has created a list of services that the bank offers (checking, savings, loans, investments, etc.) in a creative design. The window cling will only be visible inside the bank. The bank name, member FDIC, Equal Housing Lender and Not, Not, May are not included on the window cling. Can we omit these disclosures since it is in the lobby and the list is generic?

Reg DD Apply to NOW/DDA Used for Personal?

07/08/2013

If a customer has 50% of their total sum in investment products and on occasion uses their NOW or DDA account for personal payments, would regulation DD apply? It is the banks policy not to open consumer accounts. We are Private Banking, and open accounts mainly for investment purposes but do offer for convenience,other types of bank accounts. For these instances we also require the customer to sign a certification letter that states that accounts are being maintained for facilitating the acquisition of investments and only incidentally personal, family or household purposes, which in no event will involve use of more than 50% of the account balance.

Combining Product Ads-Insurance, Mortgages etc.

08/06/2012

Our bank has numerous branches, a handful of insurance agencies, and also five office locations for non-deposit investment products. I am relatively new to the bank but not to compliance. In reviewing the bank's advertisements, there may periodically be an ad that talks about deposit products that are offered, "checking and savings accounts" and in addition may even mention "mortgages." In the same ad it may mention that we also offer insurance and investments. In the ad that refers to all these types of products, it will not state "Member FDIC" or "Equal Housing Lender" due to including the statement about insurance and investments. I am really having a hard time finding this acceptable even though one FDIC examiner has "OK'd" this type of combined ad in the past. Shouldn't the ad clearly segregate the bank's products and services from the non-deposit investments (with the required disclaimers) and insurance products? I have referred to Part 328 - Advertising of Membership of 12 U.S.C. 1818(a) etc., I just need to know if I am understanding the requirements correctly.

Loan w/ Purpose for Commercial Investments-HMDA?

05/21/2012

I have a commercial loan with two residential properties, one primary and one rental but the customer owns out right but the is not purchasing, refinancing or using any part of the loan for home improvements. Is this loan HMDA reportable? The purpose is for commercial investments into another business.

Is TIS Required for an IRA?

06/21/2010

Under 12 CFR 230 (Regulation DD), it discloses Truth in Savings disclosure requirements. I am wondering if an IRA is considered a time deposit account, and if a TIS disclosure is required for an IRA.

Business Purpose and Exempt from RESPA?

12/08/2008

I have a consumer who owns multiple 1 to 4 family rental properties. He is interested in obtaining loan on one of the rental properties for the purpose of making business investments which may include the purchase of additional investments properties. Would this be a business purpose loan and exempt from RESPA?

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Most Popular Compliance Content

Can we bar debit card access at certain merchant

11/24/2024

If we feel that a debit card holder may be heading towards becoming a collections account due to excessive state lottery and state liquor store transactions on a daily basis, can we restrict the card from being used at those MCC transaction types?

Member FDIC on the WWW

11/24/2024

Is there an FDIC requirement that the "Member FDIC" logo be on all our pages and link to the FDIC website?

Carte blanche to an Authorized Signer

11/24/2024

What are your thoughts on allowing customers to give an authorized signer access to their online banking and/or approving them to have a debit card? Would it make a difference if there is a form signed by the customer providing authroization and acceptance of liability for the transactions the signer conducts?

Audit checklist for bank as mortgage loan broker

11/17/2024

I am looking for a checklist that auditors would use when doing an audit on a brokered mortgage, specifically when the bank is acting as the broker. Can anyone give me a suggestion as towhere to find one? I have been searching the internet but have not really found anything that would help me with this.

Data breach and card reissuing

11/17/2024

We have been notified by Mastercard of a data breach and need to inform our customers who were impacted by this incident. In previous financial institutions where I have worked, we typically send a letter to notify customers about the card compromise. This letter includes the date we will be closing their card and informs them that a new card will be issued. My question is regarding the regulations surrounding this process: Can customers choose to keep their card active? If so, where does the liability lie if they experience fraud in the future? I am looking for a regulation or a Mastercard rule to implement a formal policy, as there isn't one currently in place at my current financial institution.

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