Vendor Guru Q&A - Operations

Latest Operations - Internal Controls Topics

Approval of garnishment and subpoena policies and procedures

03/17/2024

At what level should policy and procedures for handling garnishments and subpoenas be approved?

We just booked a $525,000 loan to a Director’s law firm. Did we violate Reg O?

03/17/2024

We have a Director who (together with his wife) shares ownership of a law firm. I just learned that we booked a $525,000 loan for that law firm. The loan has a rate and terms comparable to other loans. Is this a problem for Reg O?

Reg E is “use dependent”

03/17/2024

I have heard that business accounts do not fall under Reg E. How does this apply to internet banking and what about a business account that is a sole proprietorship?

Due diligence cannot rely on vendor reputation

03/17/2024

Do we really need to conduct due diligence on all of our 3rd party vendors, including fintechs? I can understand the ones that appear to be riskier, but there are some that are very well-known in the industry and are very well respected. Wouldn’t the regulators just see the same thing in our file as they did the last bank they just left?

Reg E and buyer’s remorse

03/10/2024

If a consumer purchased tires and later claimed they were defective and they filed a Reg E claim, but refused to go back to the merchant, can we deny his claim?

Records access for compliance monitoring

03/10/2024

When we do engage new vendor, especially fintechs for new digital banking products (like BNPL or Buy Now Pay Later), what type of access to records should we expect to have to be able to monitor for compliance?

EFTs & Aggravated Ignorance

03/03/2024

Why can't we hold customers liable for carrying their PIN with their card?

Responsibility for managing garnishments and subpoenas.

03/03/2024

Who should be responsible for managing the bank’s handling of garnishment orders and subpoenas?

Basic steps for Reg E claims

02/25/2024

Must we go through the formalities of an investigation and document what we’ve done such as paying provisional credit on claims that were made timely?

Is it OK to do just a little bit of cannabis banking?

02/18/2024

Management would like to cautiously bank “just one really good” customer who is getting into cannabis sales. Can we ease into it like this, and if so, what should we focus on?

Bank counsel review of policy and procedures

11/03/2024

Why should we ask bank counsel to review our policies and procedures on handling garnishments and summonses? Doesn’t that just add costs to the effort?

Must ACH authorizations be in writing?

10/27/2024

Does there always have to be a written authorization for an ACH transaction affecting a consumer’s account?

Day-forward imaging

10/27/2024

What is meant by “day-forward” imaging?

Steps for streamlining imaging workflows

10/27/2024

What steps can be taken to improve an institution’s imaging workflow day forward?

FDIC signs on drive-up equipment

10/20/2024

I'm having a discussion with others at my bank, and they are saying that they have seen other banks that have put the FDIC Decal on drive-through canisters or on drive-through machines. Is that required? I thought if you put it in the window of each drive-through station you were covered under the new FDIC sign rule.

Latest Operations - Internal Controls Topics

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