08/10/2009
Would you please provide citations that support the answer to this question: <a href="http://www.bankersonline.com/compliance/guru2008/gurus_comp050508a.html">Regulation O - Overdrafts on Insider Accounts</a>, answered by BOL Guru John Burnett?
06/29/2009
I see a lot of guru Q and A's regarding directors and overdrafts and overdraft fees. My bank's policy is to exempt all directors from our overdraft protection program, so that we don't have to worry about Reg O issues on that score, but my question has to do with a plain old ordinary non-sufficient funds fee. Is it a Reg O violation to refund an NSF fee?
06/08/2009
Regulation O states that "no bank may pay an overdraft of an executive officer or director of the bank unless ......" This normally does not apply to related interests of insiders. My question is: If the overall credit exposure of the insider or related interest exceeds $500,000, does the overdraft provision apply to related interests of the insider as well and do we need to monitor? The regulation does state that related interests are not counted, however other information received from a regulatory service says that it does.
11/17/2008
We would like to train our tellers on cross selling bank products. What are some compliance issues that the tellers need to be aware of when mentioning various products to customers?
07/14/2008
We would like to post a banner at the bank advertising free business checking. Can we advertise free business checking if the account is not totally free? If they exceed the monthly check total or have overdrafts there will be fees. The account is free up to 250 checks, so I can see where we would advertise free. It is free within the guidelines addressed when opening the account. I just want to make sure that we will be in compliance if we do this.
05/05/2008
Is it a violation of Reg O if an NSF check is posted against an insider’s account with insufficient funds (for more than $1000) and the process for reviewing/returning or paying these NSF items happens the morning after the item was posted to the account? The insider's account statement would show one day overdrawn for greater than $1000.
04/14/2008
We are adding a new fee to overdrafts where we will be charging a continuous overdraft fee after being overdrawn for five days. Are we required to notify customers beforehand? Also, are we required to send a notice when this charge has been assessed?
10/01/2007
Is there a regulation that prohibits a bank from offering a business customer the ability to use a savings account to protect a business checking account from overdrafts or from just making transfers via the internet or phone? I am aware of the transaction limitations under Reg D, but a co-worker believes there is a regulation that prohibits transfers from an interest bearing account to a non-interest bearing account for businesses.
07/30/2007
Under the requirements of the new rules for overdraft protection programs under Reg DD, there is an exemption for the historical information on overdraft charges for banks being purchased by another institution. If both the existing bank and the bank being purchased are required to disclose the annual history of charges due to advertising the overdraft program, does this exemption still apply?
03/19/2007
If we close a deposit account due to repeated overdrafts do we have to send an adverse action? No credit report was pulled to make the decision.