Most Popular Compliance Content
Sign Up for E-Statements Here
05/05/2008
When we open new accounts, we like having customers sign up for online banking at that time. Marketing created a form where the customer waives the requirements for demonstrable consent and certifies they meet the hardware and software requirements we have to get our e-statements. Is this satisfactory?
Regulation O - Overdrafts on Insider Accounts
05/05/2008
Is it a violation of Reg O if an NSF check is posted against an insider’s account with insufficient funds (for more than $1000) and the process for reviewing/returning or paying these NSF items happens the morning after the item was posted to the account? The insider's account statement would show one day overdrawn for greater than $1000.
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?