Most Popular Compliance Content
Small Bank CRA Statement
05/05/2008
Does a small bank need to have a CRA statement?
$100 for Opening an Account with Direct Deposit
05/05/2008
Our bank would like to pay $100 to every customer who opens a checking account and signs up for direct deposit. The incentive would be paid to the account upon confirmation of the service, which could be 30-60 days from account opening. In looking at the requirements of 217.101(b), I'm concerned that an examiner could argue that duration and minimum to open an account is a factor in the promotion. It goes without saying that an account would have to be established to hold the funds and I understand that direct deposit is an ancillary service. At the same time, the whole objective of the promotion is to get new customers and new accounts. Is this promotion risky from a compliance standpoint? Should we consider this non-employee compensation for IRS reporting purposes?
HMDA Reporting - Commercial Loan Refinancing
05/05/2008
The bank made a commercial loan that included a 1-4 family dwelling as an abundance of caution. The commercial customer is now refinancing the commercial loan and the 1-4 family dwelling will again be part of the collateral package. Should the loan be reported on HMDA as owner occupied? The owner of the property is occupying the dwelling, however, the vesting of the property is not in the borrower's name. If it is owner occupied would government monitoring be required?
Confused Over Reg CC's Standard & Extended Holds
05/05/2008
My question deals with Reg CC holds. I am new to the compliance department, but I have been a teller and an auditor. Since I have been in banking I was always told that a standard hold was 2-5 days and an extended hold was 7-11 days. Now there is some confusion to whether this is correct. The auditor and I have been discussing this and we have somehow confused each other. Can you place a standard hold on a local check from 2-5 days or, once you hit the 5th day does it become an extended hold? Can you vary off the days such as a standard hold for 4 days or an extended hold for 9 days or should it be strictly 2,5,7, or 11 days? We have read the regulation as well as documentation from a compliance certification program and we just can't decide.
ATM Lighting Court Cases?
05/05/2008
Are the gurus aware of court cases involving ATM lighting? Specifically below standard lighting.