11/24/2024
We have a savings account with an ACH that we are returning NSF. Can we charge the NSF fee if the ACH would have overdrawn the account?
09/01/2024
Is an email consent disclosure considered "written consent" for ChexSystems? I have a lender who would like to email the ChexSystems consent disclosure to account owners and use their reply to the email as proof of consent. Does this satisfy the requirement that the consent be in writing?
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?
08/13/2023
If we provide Reg DD disclosure data such as the APY on business account periodic statements, would that require us to follow the other Reg DD requirements such as providing subsequent disclosure notices if we change an account service charge? Our host system is tying accounts together based on Social Security Numbers and Reg DD is triggered by the CIF and not by the individual accounts.
02/19/2023
Regarding the Annual Error Resolution notice required by Reg E, for online statements can this resolution just be added to the website or does it have to be actually sent to each customer with their online statement?
02/12/2023
We have changed our verbiage on our fee schedule to match the verbiage on our important terms and conditions regarding representments of checks. I was going to send out a letter with the updated fee schedule, but due to cost I would like to include the separate letter in the statement envelope. Does anyone see an issue with this?
12/11/2022
We have customers who initiate the same Reg E wires, for the same amount, to the same country, each month. The required disclosures are read to the customer each time. Can this disclosure requirement be waived if the customer sets up the wire as a Standing Order or sets up the wire to be an STO?
10/30/2022
We have customers who initiate the same Reg E wires, for the same amount, to the same country, each month. The required disclosures are read to the customer each time. Can this disclosure requirement be waived if the customer sets up the wire as a Standing Order or sets up the wire to be an STO?
03/07/2021
We need specific information on when we MUST post "MEMBER FDIC" on actual videos, ads etc. that we post direct to social media "if" this is already on our Facebook/Linked In pages in the "About" section. Please expand on this topic in detail.
06/28/2020
We have a HELOC originated in 2008 that moved into the repayment phase in May 2018. The initial rate was WSJ prime and remains at WSJ prime (no margin) throughout the repayment phase. The loan has a interest floor of 3.75 percent so the rate has been set at that since May 2018. Since there is no set change date to enter in our system the CFPB ARM notice will not generate to give advance notice if the rate increases. Are we required to provide the ARM notice, and if so are these circumstances that allow the notice to go after the fact?