02/12/2007
When a Bank has a Reg O violation, an executive officer habitually overdrawing their account and at times circumventing the OD fees, what reporting requirements apply? I am a CPA and our client is regulated by OTS. I understand they must have it listed and ready when OTS examiners come, but are there other requirements? We will make sure the Board is notified, but we need to know if we have to advise bank to notify OTS right away.
01/22/2007
What is the law/reg regarding overdrafts on bank employee checking accounts? From time to time we won't charge a good customer (long time customers who rarely have overdrafts) an overdraft fee. Since we do this for some customers can we do the same for a bank employee?
09/25/2006
Our statements did not print the overdraft charges until July 7th and our processor feels they were not out of compliance. I thought that the fees had to be shown as of the July 1st. Are they out of compliance?
09/04/2006
When must a hold be placed on an account for Reg CC? We are considering not allowing tellers to fill out the hold form, and have them done in the bookkeeping department to decrease the errors. Does the hold have to be filled out at the teller window and given to the customer and when processing the night depository?
08/14/2006
I am trying to understand the Reg D guidelines. Is the use of the 24 hour telephone teller for transfers to transaction accounts and check withdrawals mailed to the member counted within the six allowed? How do I count transfers from a non-transaction to a transaction account made automatically to cover overdrafts?
07/31/2006
We are having a problem getting our account processing vendor to make programming changes to allow us to separately identify fees for paying overdrafts and fees for returning items. We have always applied an "overdraft item fee" regardless of whether the item is paid or bounced. Our vendor tells us that we aren't required to make the change because we don't offer an overdraft protection plan. Where, specifically, in the regulation does it say we have to make this change?
04/17/2006
I am hearing that we now have to post signage on our proprietary ATMs that disclose to the customer that withdrawals at the ATM may cause them to access their overdraft privilege. Is this true? If so, what agency is mandating this? I would like to review the regulation. My understanding it that we have until July 1, 2006 to comply.
04/03/2006
Can a hold be placed on a cashier's check (not one issued by us)? If not, and the check is returned to us as counterfeit, forged, etc. what should be done? How can we protect our bank?
04/03/2006
In relation to Reg O, or whatever applicable regulation, where does it state that on the call report the Bank must disclose the entire amount of a Line of Credit? We are working on a Reg O audit, but would like to reference something concrete that states they should disclose the entire amount of the LOC, not just the current balance.
01/23/2006
If a deposit is made using $2,000 in cash and $9,000 local check what are my hold options through Reg CC?