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Latest Operations - Internet Topics

Sending Email Marketing

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?

Federal Reserve Responds to Reg D Questions

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

Banner Ad Trigger Term Placement

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?

Dealing with Senior Management About Business Continuity Planning

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!

Kids Savings Programs

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?

Advertising Non-FDIC Insured Products on Website

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?

Authorized Signer Questions

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?

Reg DD - Internet Ad

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.

Free Cell Phone - IRS Reporting

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?

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Banking marijuana-related businesses

04/06/2025

Our bank has taken a "no" stand on banking MRBs, however we recognize the "Tier III" category identifies some types of businesses that may provide services to a Tier I MRB. An example would be a container manufacturing company that may sell containers to a Tier I MRB as only a small percentage of their business. Does anyone use an allowable percentage of revenue to determine if this is within your risk tolerance? Also, is there an allowable threshold for direct sales of cannabis products in the states that have legalized use? (For instance, a liquor store or distributor that sells beverages with THC, since that is becoming so common).

Getting ID info when cashing on-us checks

03/30/2025

When a non-customer comes in to cash an on-us payroll check, we take their information from their driver's license or state-issued ID and enter it into our system. Are we legally able to ask for their Social Security number, considering they are non-customers?

To file or not to file: That is the question

03/30/2025

I have a customer who cashed a check for $10,880.00 and, after cashing, told the teller to make three separate deposits of $2000.00 each into three different accounts for which the memkber is a joint owner. Because the teller kept the cash and made the deposits do we have to file a CTR? I believe if we had given the money to the member and the member had given the teller back $6,000, a CTR would be required. But because the $10,880 was not handed to the member, the only cash transaction would be the net payout of $4,880 from the teller to the member, and a CTR would not be required.

Account service agreement for MSB accounts

03/23/2025

I need suggestions for preparing an account service agreement for MSB accounts. We have a questionnaire attached to our applications to confirm transactions, etc., but lack a true service agreement beyond our standard commercial account agreement.

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