01/14/2024
I am working with a new core system and we are discussing our exceptions process for items presented that cannot post for various reasons i.e. NSF, closed account, account restriction, etc. This system will not backdate the item to the date of presentment in cases where we choose to pay it. Is there anything that states the item must be "paid" on the date of presentment?
Every other core I have ever used in my 28+ years has always backdated the item to the presentment date.
01/07/2024
Can we waive early withdrawal penalties on CDs?
01/07/2024
We currently have outside counsel providing what I believe is inaccurate guidance. However, I'm struggling to find resources I can use to refute their regulatory interpretations. Specifically, this applies to a consumer's right to stop payment under 1005.10(c). Can you please advise how these requirements apply to:
1. Preauthorized transfers for loan payments (we are the lender/servicer) drawn on both external (we obtain debit authorization) and internal deposit accounts; and
2. Preauthorized bill payments both issued against the bank's/vendor's account and debited directly from the consumer's account. We hold the consumer's deposit account and offer the bill pay service.
01/07/2024
Reg E (12 CFR 1005.17(b)(2)) says we cannot condition the payment of checks and other transaction on the whether the consumer has opted into overdrafts via ATM and one-time debit card transactions. However, it does not clarify whether the opposite is allowed – meaning can you condition ATM and one-time debit card transactions on whether someone has opted into overdrafts via check and other transactions? I can't find any guidance on this question, so any advice is much appreciated.
12/31/2023
Are savings account withdrawals still limited to 6 per month?
12/31/2023
Where in the regulations does it spell out the time limits and liabilities for banks regarding counterfeit checks, altered checks, forged endorsements, etc?
12/31/2023
What is the time frame to return a check which was forged or fraudulently altered, i.e. stolen and washed?
12/24/2023
Bank management wants to simplify our account lineup and get rid of NOW accounts. I thought these accounts were the only way we could pay interest on certain checking accounts. Are we shooting ourselves in the foot by getting rid of them?
12/24/2023
What is the timeframe on doing a check adjustment for a item paid twice? Mobile item posted to our customer on March 31, 2022 and then again on May 3, 2022.
12/17/2023
We allow customers to open deposit accounts online. We’d prefer to keep disclosures (especially our rate and fee sheets) off our website, so that the competition can’t see them. Must we provide TISA disclosures up front, or can we mail them later? I seem to remember Reg DD allows us to send disclosures up to 10 days later when the customer isn’t at the bank.