07/06/2009
When a user agrees to internet banking and e-statements, we include an authorization that consents to our sending marketing solicitations. Since we have their consent already, would this be subject to the CAN-SPAM rules and the opt-out requirement?
05/26/2009
IMPORTANT NOTE: Effective July 2, 2009, the separate treatment of third party payments by check, debit card, draft or other similar payment orders is ended by an amendment to § 204.2(d)(2) o
03/30/2009
The new advertising rules under Reg Z require disclosures to be in "close proximity" to triggering terms. How can this be done in a website banner ad?
12/12/2008
How do you get Senior Management to buy into the serious need for business continuity planning, including the need to spend money for adequate back-up materials, filters, etc.? We recently were hit with a computer virus and were without internet for 4 days. We should have a back up method for that!
11/17/2008
We have a kids savings program that pays a quarterly bonus based on the number and dollar amount of deposits made. What we are finding is that grandma makes the minimum deposits for the kids so they earn the bonus and it is expensive. How can we re-tool this to increase usage?
09/22/2008
08/25/2008
I have recently taken over the compliance role for our banks internet banking department. I understand that when we are advertising securities products, we have to ensure that consumers are aware the product is not FDIC insured and may lose value. Our product marketing team utilizes banners on our website pages for advertising purposes. Of course I would prefer that banners advertising FDIC insured products not be allowed for pages advertising non-FDIC products such as insurance and securities. Are there regulations to support my preference. If so can you provide them to me, or should I allow both product types on the same internet page as long as the disclaimers specifically explain the FDIC coverage?
06/16/2008
I am confused as to how much information or access can be given to an authorized signer on a business account. Can they receive balance information, access internet banking and have a debit card? Can there be more than one authorized signer on the same account? Do the regulations vary from state to state?
03/17/2008
I am fairly new to the deposit compliance arena. Under the advertising section of Reg DD, there are exemptions for certain types of media (<a href="http://www.bankersonline.com/regs/230/230-8.html">230.8(e)</a>). One of these exemptions is broadcast or electronic media, such as television or radio. Would an advertisement on our bank's website be categorized as electronic media, and thus exempt from certain disclosure requirements, or would it be considered just like print media and thus be subject to all requirements of <a href="http://www.bankersonline.com/regs/230/230-8.html">230.8(c)</a>? I think that it should be treated just like print media, but I am having a difficult time finding any regulatory guidance to either confirm or refute this.
12/17/2007
We would like to offer a free cell phone and phone service for one year (including Internet access) to commercial customers who open a commercial checking account and sign up for online banking. Is the value of the phone and the service reportable to the IRS?