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.
07/08/2013
Our member states he made a withdrawal from an ATM machine and as he was about to get into his car he was robbed. Does Reg E cover the members claim?
07/08/2013
Does federal regulation prohibit Sunday closings?
07/01/2013
Is it acceptable for FIs to write off small dollar amounts?
07/01/2013
A customer deposits at another bank through an ATM. We need pictures of the checks that make up the deposit. The bank says we need an Reg E Claim Form. Is this correct and what is a Reg E Claim form?
07/01/2013
Regarding HMDA, we have two different answers as to what defines a Bridge loan. They are basically the same answers with one exception: if the loan is secured by BOTH dwellings (existing one and one to be purchased); OR if the loan is secured by ONE dwelling (either existing or one to be purchased). As I said, I understand consistency is the key to remaining violation free in this area, but again, I would like to know how the majority views this detail of a Bridge loan.
07/01/2013
I have a customer that pays his utility bill by direct debit. He has informed us that he just noticed on his banking (checking) statement that 2 ACH debits are debited from his account monthly by my company, and have been for the past 7 years. He never noticed the second debit because he keeps a large balance in his checking account. Upon review we found that the second monthly debit was a direct debit charge from a different consumer. He claims this is fraud and the debits were unauthorized for 7 years. They want to recover all of the unauthorized funds stating there is no time limit and we should follow the States statue limitations of seven years. Is this correct? I can't find any time limits in any of the NACHA rules.
06/24/2013
If you are filling out a CIP for a new customer and the customer is on disability, what should you put in the field for employer and occupation?
06/24/2013
We have an auditor questioning Regulation CC and its relation to Subpart C 229.33(d). If we have a loan customer who makes a check payable to our bank for payment, and the paying bank says its being returned for NSF, are we required to send our loan customer written notice of nonpayment under this section of the regulation?
06/24/2013
Our company supplies software for banks and credit unions. Many of our clients offer HSA accounts. We have been asked more than once about how to account for a reimbursement of a distribution that ended up being for a non-qualified expense. So say someone uses their debit card to purchase something they thought was qualified but later finds out it is not. Instead of taking the penalty on that withdrawal, they would like to reimburse the account for that expense and in essence, make it disappear. Is that possible to do from a compliance standpoint?