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Latest Operations - Discrimination Topics

Pre-approved Home Equity Loan Promotion

03/13/2006

We want to start a promotion where we notify customers that they have been pre-approved for a Home Equity loan, what guidance can you provide and what regulation should I look at?

Would This Be Discriminatory?

01/30/2006

Can you offer a special checking account to a select group of people, ie: they all work at the same place, without discriminating against other customers if they are not employed by the same company?

Marketing Club Account to Young Professionals

08/01/2005

Our bank is considering a "club account" marketed towards young professionals. I know on the lending side we have ECOA and fair lending to take into consideration, what areas of potential discrimination should we consider on the deposit side? I have read the question answered by Andy Zavoina entitled Is Free Checking for 50 and older an ECOA violation? Are there other regulatory areas to take into consideration?

CDs Only Offered in Bank's Geographic Market Area

02/21/2005

We will be offering CDs tied to money market accounts, both at premium rates, for a short time as a way to get new customers in the door. We do not want to offer these accounts to people outside of our geographic market area. If we have a "no out of area accounts at these rates" policy, are we required to disclose that in print advertising that only runs in our local area?

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Customer okays purchase but doesn't get the goods

03/16/2025

A customer authorized a transaction with Apple Cash but says they didn't receive anything. Since this transaction was authorized by the customer, is this covered under Reg E's error claims rules?. The customer was attempting to purchase something on Facebook marketplace but never got the item.

Extended OFAC records retention period

03/16/2025

My question is about the new OFAC retention rules effective March 12, 2025. What records are covered? Will OFAC checks at new account opening need to be kept 10 years now or is the new rule just for hits and blocked property?

Debit card logistics for banks without deposit account

03/09/2025

I have two questions relating to debit cards: 1. Does a bank have to have an ABA routing number for debit cards to function? 2. Are banks with no public depositor service able to use internal accounts as private checking accounts with debit cards to pay bank taxes and order supplies?

Sole proprietor changing to LLC

03/09/2025

We have a sole proprietorship DBA account under a Social Security number. The customer now has an LLC with an EIN. Do I need to change the account number or just update the signature card to reflect the LLC as the Primary and remove the DBA on the account?

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