Most Popular Compliance Content
Open-end lines and HMDA
02/05/2017
If we are required to report open-end lines of credit for HMDA in 2018, will this include, unsecured credit cards and/or commercial lines of credit?
Relocating Contents of Safe Deposit Boxes (SCRA)
02/05/2017
We are closing a branch and there are safe deposit boxes that are protected under the SCRA. We're thinking it's okay to drill the boxes and relocate the contents to another safe deposit box at another branch. Would you agree that this is okay to do?
Limitation for Loans Not Contracted Under UCCC?
02/05/2017
Could you give me your thoughts? Most believe Remote Deposit of check images are subject to Reg CC mandates. I have observed on BOL that this is not the rule, but is a best practice?
Parameters On Banks Giving Bonuses to Customers
02/05/2017
I would like to know what (if any) parameters surround banks giving bonuses to customers. I am familiar with the typical $10 refer a friend program but I am looking at amounts exceeding $10,000 on more than one occasion. The bonus or referral fee (I’m not sure how it is categorized) is paid based on how many people sign up for pre-paid cards on a monthly basis. I was able to find this article (noted below) but I think it misses the mark regarding what I’m looking for. The reason why I saved this article was the bonus payments I’m referring to do not fall within the guidelines of numbers 1-3. “Now let’s look specifically at Regulation Q and what it has to say about paying a bonus on an account. In fact, §217.101 is specifically titled “Premiums on Deposits.” (a) Section 19(i) of the Federal Reserve Act and 217.3 of Regulation Q prohibits a member bank from paying interest on a demand deposit. Premiums, whether in the form of merchandise, credit, or cash, given by a member bank to a depositor will be regarded as an advertising or promotional expense rather than a payment of interest if: (1) The premium is given to a depositor only at the time of the opening of a new account or an addition to an existing account; (2) No more than two premiums per account are given within a 12–month period; and (3) The value of the premium or, in the case, of articles of merchandise, the total cost (including taxes, shipping, warehousing, packaging, and handling costs) does not exceed $10 for deposits of less than $5,000 or $20 for deposits of $5,000 or more. “ http://www.bankerscompliance.com/~bcc/assets/files/articles/Bonus_on_Acct_+_Flowchart.pdf
Adverse action reasons
02/05/2017
In regards to the check box options on an adverse action notice, as a commercial lender, I would like to add “Length of time in business is too short” as we do deny credit to many newly established companies (per our credit policy). So my question is this: Can I create my own reason or is there a specific set of reasons that I need to adhere to? Where does ‘length of time in business too short’ or verbiage to that effect fit on an adverse action notice?