07/08/2013
If a customer has 50% of their total sum in investment products and on occasion uses their NOW or DDA account for personal payments, would regulation DD apply? It is the banks policy not to open consumer accounts. We are Private Banking, and open accounts mainly for investment purposes but do offer for convenience,other types of bank accounts. For these instances we also require the customer to sign a certification letter that states that accounts are being maintained for facilitating the acquisition of investments and only incidentally personal, family or household purposes, which in no event will involve use of more than 50% of the account balance.
07/01/2013
I have a customer that pays his utility bill by direct debit. He has informed us that he just noticed on his banking (checking) statement that 2 ACH debits are debited from his account monthly by my company, and have been for the past 7 years. He never noticed the second debit because he keeps a large balance in his checking account. Upon review we found that the second monthly debit was a direct debit charge from a different consumer. He claims this is fraud and the debits were unauthorized for 7 years. They want to recover all of the unauthorized funds stating there is no time limit and we should follow the States statue limitations of seven years. Is this correct? I can't find any time limits in any of the NACHA rules.
06/24/2013
My question is about the fee summary at the end of a checking statement. The Total for this period column would be for that specific statement cycle. The Total Year-to-Date column is where my question comes. Assuming that an account had NSF/OD from 12/18/12 thru 12/28/2012 and the statement cycle was 12/18/2012-1/17/2013. The first statement printed in 2013; the Total Year-to Date field should be zero, correct; however the Total for this Period would include the fees for the entire statement cycle. From a compliance perspective, the Total Year-to-Date column would be missing any fees that happened between 12/18/2012-12/31/2012 correct?
06/03/2013
Can we change the business address on the system from the owners home address to the address where the business is conducted without written authorization from the business owner?
05/20/2013
What are the financial reporting requirements for Directors and their related interests under Reg O? Do they need to produce tax returns or appropriate financial statements annually for their personal loans and loans to their related interests?
05/13/2013
Do the Letters POD have to be in the address information on the bank statement as long as the POD information is designated on the signature card? I understand the account title has to match the card- but does POD HAVE to be there?
03/25/2013
How long do we have to keep copies of credit card statements and reports. We have some from 2007.
03/11/2013
We would like to start a campaign to encourage our Merchant Service customers to switch from paper statements to e-statements. First Data does not require anything other than an email from us once we have received the merchant's verbal approval. Does switching our merchants from paper to e-statements require we comply with the E-Sign Act?
02/04/2013
What is the record retention requirements on business deposit accounts once the account has been closed?
01/14/2013
Should the words POD appear on a customer's bank account statement if it appears on the customers account agreement?