Most Popular Compliance Content
Insiders and Overdrafts
07/16/2023
An executive officer has a debit card transaction that has caused an overdraft. As to Reg O, we would pay and charge the fee. But as to Reg E he has opted out which means we would pay the item and not charge the fee. I don't know which Reg takes precedence. The account is overdrawn less than $100.
Lobby Advertising
07/09/2023
We often have lobby posters advertising products, services, benefits like trips on a discounted price and others things on display so staff can answer questions on these and to promote these items. Do they require the general FDIC advertising statement>
Reporting winners to the IRS
07/09/2023
We ran a contest and no prize was over $300. We didn’t need to collect non-public private information from the winners since the prizes were small, did we?
A bake sale by any other name…
07/09/2023
Every year we do a bake sale to raise funds for Breast Cancer Awareness/Local Hospital Foundation. Is this acceptable?
Advertising rates
07/02/2023
If we price HELOCs based on the applicant's credit score and loan to value ratio, so some borrowers get a lower rate than other borrowers, can we disclose the lower rate in our advertisement, or do we need to disclose both rates? Do we also need to specify the criteria for receiving the lower rate?