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?
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
I have been sifting through the Reg D and NOW account information but am struggling to get the answer to a very basic question. Can we offer a business checking account with unlimited transactions that pays interest to all business customers (LLC, corporations etc.)?
03/25/2013
Is a small community bank required to have a Cashier or CFO? Is it enough to just have a controller?