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Latest Compliance - NOW Accounts Topics

NOW Account Eligibility

07/10/2009

Doesn't the IRS automatically consider a sole owner LLC to be a sole proprietorship (unless they have elected to be treated as a corporation)? As such, would this sole proprietorship not be eligible for a NOW account?

Short History of NOW and MMDA Accounts

10/09/2006

I'm looking for someone who remembers when MMDAs and NOW Accounts were legalized for banks. Seems like MMDAs were first, the fall of some year, then NOW Accounts were authorized at 5.5% for commercial banks on January 5th of the next year. Was that 1980-1981? I'm trying to educate some younger bankers on Reg D and the history of reserves, NOW Accounts, etc.

Stubborn President & Reg D's Phone & Net Transfers

07/24/2006

I am unable to convince our bank president that telephone transfers and internet transfers are counted in the six that may occur each month on a savings account. I have downloaded the Reg D chart and the law, but he is still not convinced. Can you tell me where I might find more to show him in a clear manner?

Check 21 notices to ALL accounts?

01/03/2005

We are getting ready to send out our notices for Check 21 and are a little confused. It states that it affects ALL types of deposit accounts. We currently have the following products:<ul><li>Money Market Account<li>Super Now Accounts<li>Statement Savings<li>Regular Checking<li>Time Accounts<li>Christmas Clubs</li></ul>Are we required to send to all?

Small Business Accounts

12/01/2004

Question: What should we tell a small business owner who insists on an interest-bearing checking account?

Reclassifying Savings with EFT Access

11/15/2004

This is a Regulation D question regarding savings accounts. We are looking at moving the balances of all savings accounts that have ACH debits currently set up, as well as all accounts that have an ATM or debit card, into a separate general ledger and classifying those accounts as "Transaction Accounts" for call report purposes. These accounts would not be closed or transferred to another type of account. This would leave the savings accounts as they are now. This would be an internal move only of the balances to a transaction account that the customer would not be aware of. The accounts would continue to earn interest and the customer would continue to pay the bank's excessive W/D fees. Would this eliminate the necessity to notify customers of limitation requirements on existing accounts? Could this make monitoring of any of the savings accounts possibly unnecessary? Could you continue to pay interest on this type of account? Or would this be considered a total violation of Reg. D?

Check 21 notices to ALL accounts?

10/25/2004

We are getting ready to send out our notices for Check 21 and are alittle confused. It states that it affects ALL types of deposit accounts . We currently have the following products:<ul><li>Money Market Account<li>Super Now Accounts<li>Statement Savings<li>Regular Checking<li>Time Accounts<li>Christmas Clubs</li></ul>Are we required to send to all?

NOW Accounts

09/01/2004

Question: We keep hearing from management that they think Regulation D has been changed to allow NOW accounts for business or to allow unlimited transactions on savings accounts.

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Stopping Preauthorized Payments

10/20/2024

We currently have outside counsel providing what I believe is inaccurate guidance. However, I'm struggling to find resources I can use to refute their regulatory interpretations. Specifically, this applies to a consumer's right to stop payment under 1005.10(c). Can you please advise how these requirements apply to: 1. Preauthorized transfers for loan payments (we are the lender/servicer) drawn on both external (we obtain debit authorization) and internal deposit accounts; and 2. Preauthorized bill payments both issued against the bank's/vendor's account and debited directly from the consumer's account. We hold the consumer's deposit account and offer the bill pay service.

'Member FDIC' in trust department ads

10/13/2024

Our bank has a trust department and they want to run an advertisement. Does "Member FDIC" need to be included in the ad? The ad will state something like, "We can help you with your Trust and Estate Planning."

Certificate of Deposit

09/29/2024

I am new to the compliance function so I apologize if this does not make sense. My question addresses Reg DD and a CD interest payment date vs. maturity date. Here is an example: a CD term is 6 months and interest is paid every 30 days. Since there are more/less than 30 days in some months the interest payment date does coincide with the maturity date, so there are generally a few days between these dates. I am unable to find anything in the TISA reg about this. How and when is interest paid in relation to the maturity of the CD?

Unauthorized Authorized Debits

09/29/2024

If a customer authorizes someone to use their card and gives them the PIN for a specific transaction, and that someone uses the card for additional transactions that were not authorized by the customer, is their any negligence by the customer for giving the card and PIN for the first authorized transaction? What are the requirements according to Reg E ?

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