04/22/2013
Our CD (Bankers System copyright) has the language: <i>We may change any term of this agreement. Rules governing changes in interest rates have been provided. For other changes we will give you reasonable notice in writing or by any other method permitted by law. If any notice is necessary, you all agree that the notice will be sufficient if we mail it to the address listed on page one of this form. You must notify us of any change.</i> Does this allow us to change our early withdrawal penalty by a mass mailing to all of our CD customers with a 30-day notice of the change? Also, do we need to be specific by account or can we just provide a chart that shows all of the new penalties?
04/22/2013
An individual has a store credit card at a department store, they go to the department store and make a payment using their debit card. They throw away the receipt. The payment has not posted to their department store account but we can see it debited from their bank account. They are getting the run around with the department store about finding the payment. They want to file a Reg E dispute. Does this transaction qualify as unauthorized?
04/15/2013
How long can you place a Hold on a Large Check Deposit made to a Savings account?
04/15/2013
Regulation O-we have an executive officer who has a first lien mortgage on his primary residence. He thought this residence was sold, and purchased another property which he mortgaged with us. The first property sale fell through so currently both properties are on the bank's books. I assume we are in violation but would like some verification.
04/15/2013
A borrower already owns his land. We give a construction loan and in a second transaction, we payoff construction loan with permanent financing. Is this loan rescindable due to the borrower already owing land and no transfer of title takes place?
04/15/2013
If an individual is already on active duty (either regular component or an activated Guard/Reservist) when they obtain a loan, separate or get released, then reenlist or get recalled to active duty, are they eligible for the 6% rate as result of the new period of active duty (even though they were active duty when the originally obtained the loan?
04/09/2013
Must we tell our customer about an exception hold before notifying him by mail?
04/08/2013
Should our trust dept allow transfer from a self directed IRA to an attorney's IOLTA account for an investment when there is no fiduciary relationship with the attorney?
04/08/2013
If a customer opens a new account and is given Reg E disclosures at that time and later requests an ATM or debit card, do disclosures need to be provided again with the card even if they are the same as previously provided? What is considered close proximity?
04/08/2013
I just received two amended CTRs I had filed on 9.11.11 before they changed the rules for amended CTRS. At the time I attached a amended form with just the information that was incorrect on the original CTR. The rule changed on 10.31.11 stating that you made out a complete new CTR indicate it as amends prior report. So now it is 2013 and I have two CTRs to try to efile and can't find any instructions anywhere on how to do this. I tried to file FinCen CTR but it asks for a DOC # 14 numbers long; which of course I do not have. Do you have any idea where to find the documentation to show how to do this?