06/01/2004
When the lifeguard says it's not safe to go into the water, it is generally a good idea to stay out - and dry.
06/01/2004
Regulatory burden is real. And it inhibits what a business can do. Sometimes banks bring it on themselves. This is certainly the case with overdraft protection.
02/23/2004
If my bank offers overdraft protection in the form of a savings or money market as a back up account for the primary checking, what, if any, additional disclosures are required? We obviously provide Truth in Savings, account agreements, Reg E, etc.
02/02/2004
Can a home equity line of credit be set up contractually to also be used as overdraft protection (i.e., an automatic sweep from the line to cover any overdraft that may occur in the customer's checking account)?
12/01/2003
I would like to know your thoughts and/or concerns on credit scoring at the new accounts desk. Meaning, a customer opens a checking or savings account, the bank pulls a credit report to see if the customer would meet a predetermined criteria for crossselling purposes, for example, overdraft protection. In a nut shell, this is prescreening. My initial concern is that the bank does not have a permissable purpose to obtain a credit report, unless the customer is informed and provides written permission. My second thought is if the customer does not meet the predetermined criteria and is not offered a credit product based on information contained in the report, the bank would be required to provide an adverse action notice. Do you see any additional concerns/prohibitions, or know if this type of practice is acceptable?
08/01/2003
We are seeing a great deal of discussion about the evils of many kind of lending, and the evils of many financial industry practices.
05/05/2003
We offer Overdraft Protection for Business Accounts. Should all of the accounts that are tied together for the protection be titled the same?
02/10/2003
Can an overdraft protection line of credit be tied to a commercial DDA?
10/07/2002
When the bank is using an Overdraft Protection product, is there a reg that says: 1. We cannot overdraw a person's account for the loan payment? 2. We cannot charge a fee if the account is overdrawn because of the loan payment?
08/05/2002
This is a Regulation D question regarding the transfer of funds from a savings (or MMDA) to a transaction account like a "sweep" for overdraft protection. I have always heard that this is one of the types of transfers that does count against the six allowed per statement cycle. However, I just noticed, in 204.2(d)(2), in the portion of the paragraph that describes transactions that do not count against the limits, the following: "an account is not a transaction account by virtue of an arrangement...that permits the transfers of funds from this account to another account of the same depositor at the same institution". This sounds like a typical "sweep" transaction from a savings account to a transaction account. Please explain the difference.