06/06/2011
Does REG E apply to disputes submitted for reasons other than fraud and funds transfer (such as service and or quality)?
04/18/2011
Do we have to have job specific training for BSA?
02/28/2011
I once read something that stated the Equal Housing Lender logo (EHL) should be displayed anywhere a home loan application is received. Should a national bank have the EHL logo displayed on each loan officer/customer service desk where home loan applications are received or is the lobby poster sufficient?
01/10/2011
What is a "security committee"? We already have BSA, Compliance, Human Resources, Audit and Executive Committees.
01/03/2011
I understand that Reg Z requires us to set up an escrow account for HPMLs. Can a customer choose to pay the taxes and insurance and not have it escrowed? My customer is a rancher and pays all her insurance and taxes with proceeds from the sale of cattle once a year. Her insurance covers all of the farm and operations, not just the house.
10/18/2010
When we have a customer who exceeds the transaction limitations on a savings account due to online transfers, we restrict him from online banking. If he also has a sweep set up for overdraft protection, we do not remove the sweep, since this is not what put him over the transaction limit. Is this a violation of the Reg? Should we restrict him from online banking as well as remove the overdraft protection sweep?
08/02/2010
Can a safe deposit box have a POD attached the way checking or savings account can?
07/12/2010
We do a lot of targeted marketing in our bank. Our operations and marketing departments have approached our compliance team with a proposal to market our overdraft service to customers who don't yet have the service, but have had checks returned for insufficient funds in the last six months. Currently, this service allows qualified customers' accounts to go overdrawn by from $200 to $300 provided they cover their overdrafts within fourteen days. We would market it in two layers, with an option for customers to accept basic coverage for checks and ACH items only, and another to accept coverage for checks, ACH and ATM/debit card transactions. We will include all the compliance disclosure, opt-in and confirmation requirements for card transactions required by Regulation E. Are there any compliance concerns related to targeting this marketing to that group of customers?
09/22/2008
What position (head teller, loan officer, etc.) of the bank would be the best candidate for our BSA officer? Would it be our compliance officer?
07/14/2008
I'm a former assistant Compliance Officer now working in our Operations Department. I have a discussion going with the new assistant Compliance Officer regarding a BSA question. We had a customer deposit $10,000 in cash in a personal account, then purchase an Cashier's check for $7,500 for a total of $17,500 in cash. I was always under the impression a CTR overrides an MIL, but the new assistant is saying that we need to complete a CTR and a MIL. I'm saying we only need to complete a CTR. Who is correct? Where is this addressed in the regulation?