01/06/2003
We have an automated telephone banking system which has the capability of having a rate quote feature. The system is available only to customers with open accounts. Would advertising regs be applicable? For example, (on closed end loans) - one of the selections could be "For a 30 year fixed rate with zero points press 1". Would the response need to include not only the rate, but the APR, terms of payment, and the amount or percentage of downpayment? It would be so cumbersome to have to "say" all of these things not to mention, changing them as the rates change. I am familiar with all the triggering terms and such in the regs. We include all of the required items in our newspaper and Internet advertisements. We would quote savings and CD rates as well.
01/06/2003
There are many new sofware products being offered today to assist in 'verfifying' the identity of new and/or existing bank customers (per proposed rules of the USA Patriot Act). These software packages search a number of various databases to get background and other 'verification' data. Some of the data bases that are 'searched' appear to be readily accessible general public record data bases, but others appear to be data bases that are not so accesssible by the general public. Is it permissible to have a customer sign a form which essentially says that the customer agrees that the bank can search for information to verify the customer's identity without specifically identifying the data bases being searched?
12/02/2002
A customer has been appointed guardian for his mentally retarded brother. He wishes to open an account for the mentally disabled brother to deposit his SSI check and a check from an opportunity center. 1) Does there need to be a separate account for the SSI? 2) How should the title on be listed on the account, since the brother is not capable of writing checks? 3) What documentation other than the attorney's appointment of guardianship do we need for the account?
03/11/2002
A couple of our customers have had problems getting their CD's from a large bank. They have notified the bank a couple of days prior to the maturity date that they do not wish to roll-over the CD and would like the funds wired to them on the maturity date. The bank in question claims a ten-day waiting period (without payment of interest) and then refuses to wire or fed-ex funds (even though the customer wants to pay the appropriate fee). They state they can only mail a check which causes an additional 2 - 3 day delay. (To make money from the float, no doubt.) I can see in the reg's that you don't have to pay interest during the grace-period (if you disclose it), however I am completely at a loss as to why they wait ten days and refuse to wire. Have you heard of this practice? Also, where in the regs does it address prompt payment of funds to the customer?
03/04/2002
The holding company my bank is an affiliate of also owns an insurance agency in our market area. I recently saw a marketing brochure of theirs (my bank's Marketing Director acted as a consultant on the piece) that references that my bank and they are corporate partners. In the brochure are the types of insurance they sell, to include life, and the products they offer such as IRA's. There are no FDIC disclosures or NDIP disclosures in the brochure. Do we have a regulatory problem?
03/04/2002
A government entity has 5 savings passbook accounts with my institution. Each account has a separate name (e.g., ABC Project I, ABC Project II, ABC Project III, etc.) The government entity is named as the trustee for each of the accounts. And each account has the same tax identification number. My question is this: Are each of these accounts insurable by FDIC for $100,000.00?
02/11/2002
Are there any online banking courses that you reccomend? I am looking for a site the offers Rules and Regs training as well as soft skills. I would like to roll this online training out to all of our branches in Texas.
02/04/2002
Can you barter for the cost of ad production?
01/07/2002
I work in a small bank and our compliance officer is no longer with us, is there a list of compliance training that we are required to do each year with our employees. I am getting into the compliance end of operations and need some guidence till I can get some training.
12/03/2001
Is it allowable to xerox a person's driver's license photo? Some tellers were doing this for non-customers cashing checks at our bank, but another employee says we cannot do that.