04/08/2013
A bank sends out a customer statement to another person by mistake. Has the bank violated Reg P? If not, can you cite any exemption?
04/08/2013
Is it part of a government regulation to ask your customer where he/she received or why he/she is taking out a large sum of money? If so, which regulation is that part of?
04/08/2013
Currently, when a customer signs up for estatements we still send a paper statement. The paper statement turns off when they open their first estatement. Are we required to do this or can we turn the paper statement option off completely when they sign up for estatements?
04/01/2013
A customer's savings account is set up to protect his checking via overdraft protection and he has violated Reg D for three consecutive months and the bank has removed the overdraft capability, following all requirements of course. When can he or can he request overdraft protection from his savings to his checking again?
04/01/2013
We are a small community bank that does not offer an overdraft program. We elected to opt out of the Reg E amendment effective July 1, 2010 and are paying one time debit card transactions that overdraw accounts without charging an NSF fee. Obviously we are losing income because of this. We are wondering if we could charge a reactivation fee on the debit cards that have overdrawn for the second time. Example: customer overdraws account with one time debit card transaction. We suspend the card. The customer deposits and we unsuspend. The customer does it again, we suspend, they deposit and we charge a reactivation fee to reactivate the card the second time. Is this ok? If not, can we charge an annual fee on debit cards?
04/01/2013
Our customer gave their 9-year-old child permission to buy a book on the Internet through Apple ITunes in the amount of $9.99. While in the website the child was looking at a lot of other things. Next day 12 charges came through their account totaling $373.44. They want to dispute as they only authorized $9.99. When they talked to the child he said he looked at lots of stuff but had no idea he was purchasing what he looked at. The parents called the number on statement and it directed them to a website which they emailed. We told them to let us know when they hear back which could be 48 hours. Can they dispute the difference?
04/01/2013
We require password changes monthly at our bank. Is there a regulation or guidance that required changes that frequently? I understand more is better, but it is also a huge cost to the bank.
04/01/2013
If a UCC-1 is filed/recorded with the county, does it expire in five years like a UCC filed with the state does? If so, is the best practice to record a continuation with the county prior to the expiration date of the UCC?
03/25/2013
Under CRA, what constitutes a commercial or Industrial purpose? I have looked for a definition to no avail. Would this include a loan to a small business for a capital injection?
03/25/2013
In reference to this discussion: Question: I am currently going through a review of ATM/Reg E procedures with our internal Compliance dept. They are requesting that we apply interest to disputed Reg E amounts because of the Deposit Compliance Program. I have not heard of having to apply interest to disputed Reg E transactions. Should we be applying interest on transactions that are disputed under Reg E?Answer: Yes, you are required to credit a customer for lost interest when they make a Reg E claim. This is addressed in <a href="http://www.bankersonline.com/regs/12-1005/12-1005-011.html">1005.11(c)(2)(i)</a>The question I have is...if the interest owed is less than one cent, do you still have to post it by rounding it up to one cent?