Most Popular Operations Content
Disclosing "posting order" when explaining when OD fees may be charged
07/28/2024
If we elect to update our disclosures on the circumstances that may trigger overdraft charges, do we have to disclose the order in which we post debit and credit items to deposit accounts?
Identifying "protected funds" under Treasury's garnishement regulations
07/28/2024
Two of our depositors receive direct deposits of both VA and Social Security benefit payments to their joint checking account. We received a garnishment order naming one of them as judgment debtor. When we looked back over the past two months’ account activity, we found two direct deposits for Social Security benefits and two for VA benefits. These customers routinely move their SSA and VA deposits into their savings account soon after they are received, and appear to meet their monthly bills using monthly IRA disbursements. Can we treat the SSA and VA funds in the savings account as “protected funds”?
Exceptions and audits
07/28/2024
How can exception management impact audits?
Authorized signers on CD accounts
07/21/2024
Can a personal certificate of deposit account have authorized signers?
APSN ATM/POS transactions and overdraft fees
07/21/2024
Our institution has chosen not to charge NSF fees on ANY ATM/debit card transactions whether they are one time or recurring. Having said that, if we are in an APSN situation at end of day and the account is now overdrawn, we DO charge an Overdraft Fee (even if the only item causing the overdrawn balance is the ATM/Debit card transaction). Would this be perceived at UDAP/UDAAP? Additionally, both NSF fees and OD fees are the same amount.