04/17/2022
I am reviewing a deposit ad for branch flyers. The Free Banking Service package includes an array of free services including free money orders, official checks, and stop payments. Should there be a disclosure as to how many and how often the customer can receive this benefit or does the statement to contact an employee for more information cover this?
02/20/2022
Our current periodic deposit account statements show all the required parts for compliance required at 1030.6(a). We show the APY Earned based on the General Formula from Appendix A-2.2.A. If we decide to remove only the “Interest Rate” reflected on all periodic deposit account statements going forward, could we be out of compliance with 1030.6(a)? Also, if we continue to leave the interest rate on the periodic statements, would it be an UDAAP issue, potentially causing confusion for consumers to see a different interest rate on periodic statements than what is on their TISA, due to fluctuations on deposits and debits?
10/10/2021
Our bank is now charging a $3 fee on paper statements in an effort to move everyone to online banking, where there would be no charge for the statement. Is this permissible by Reg?
01/10/2021
Our FI is planning on using Promontory to offer broker deposits to consumers.
I have thought that Reg DD, section 1030.4 thru 1030.6 (Account
Disclosures) apply, however the Agreement and periodic statement don't specifically
address by Reg DD the required elements. For example, their Agreement states
accrued interest will be credited "at least once each month" vs. a specific
frequency, and it does not reference if accrued interest will be paid or not
paid if the account is closed, and refers to the APYE as "Statement Period
Yield".
We have just received communication from the vendor and they are telling us
that "A Relationship Institution is a “deposit broker” for purposes of
TISA and, as such, is subject only to the advertisement provisions of Reg
DD." But they don't even spell out at least once Annual Percentage Yield.
Is our FI required to meet all the requirements of Reg DD as if the consumer
were opening one or our MMAs?
08/30/2020
We are trying to develop a Refer-a-friend program. We will offer a $50 bonus" for referring customer and a $50 bonus for the referred customer once the account is opened with direct deposit and they use a debit card a predetermined number of times in 60 days. We have a third party company that tracks referrals and bonuses which is trying to tell me I don't have to 1099 anyone because we're not paying the bonus at account opening - we're paying the bonus for meeting the qualifications of the program. Is a 1099 required for a $50 refer-a-friend bonus?
06/07/2020
We have a customer that wants to opt out of email/mail and telephone contact with us. In fact we have no telephone number on file to contact him. He doesn't want emails or letters. My question is, are we required to comply with requests for opt out to include postal items and email?
12/08/2019
Would it be considered co-mingling of funds if a customer is making business related purchases on the personal account?
11/10/2019
When advertising a CD special on a rate sheet that will be provided to customers, and the ad only indicates the CD special product name with a
statement that says, "ask us how to open your CD special," and nothing else, but the CD special has conditions and limitations that the regular CD
accounts do not, should a bank disclose on the rate sheet what those conditions and limits are that differ from the regular CD products that are
also listed on the rate sheet?
There is a fully disclosed addendum for the special that covers the Reg DD
disclosure requirements. However, this will only be provided if the special
is opened by the customer. My concern is that if the customer only requests
the rate sheet and doesn't open the account the customer will not receive
the addendum or the full scope of the special on the rate sheet and this may
be a little misleading if the customer comes back at a later date to open
the special and they find out there are conditions to be met on the product.
10/06/2019
This is about an advertisement that offers a bonus to a customer and one of the conditions to be met in order to qualify for the bonus is having a set
number of debit transactions posted to the customer's account within a specific period of time. When disclosing this qualification in the ad for
the customer, should it be specified as "posted and cleared to your account" to be more clear and conspicuous or is the language "posted to your account"
sufficient?
Does Reg DD indicate the need to specify the term "cleared or completed"
when referring to posted?
08/25/2019
Our bank is exploring the idea of a new CD product in which all the interest is paid up front on the date of initial deposit. In the case of early
withdrawal, are we able to deduct the penalty from the principal since there would be no interest accruing during the CD term?