03/13/2006
What are the disclosure requirements on Certificates of Deposit renewals under and over 12 months? I know we're required to do a new TIS disclosure for any term over 12 months, but what else is required? I know some banks send out monthly interest added back notices. Is this necessary if you are sending them a maturity notice 10 days before maturity with renewal dates, amount, and that the interest rate has not yet been calculated? They are advised in a letter to call or come into the bank for current rate at maturity. Anyway, I guess my question is: Is the maturity letter for an auto renewable CD the only required information needed to meet TIS rules?
01/23/2006
What are the ramifications of allowing additional deposits to a certificate of deposit when the contract specifically prohibits that? No additional disclosures are given to the customer upon receipt of the additional funds.
10/17/2005
Do we need to provide advance notice when we increase a fee for incoming wires? We do not consider this a fee related to account ownership.
03/21/2005
If a savings account becomes overdrawn due to an ACH item, can the bank charge an NSF fee the same as for checking accounts?
02/25/2005
05/24/2004
02/23/2004
On our rate and fee schedule (including TISA disclosures) are we required to have all our miscellaneous fees showing? Or can we use our new account brochures? And, if so, do we need the customer to sign something showing that they received the new account brochures?
06/16/2003
Does the $10/$20 value limit on premium items apply to new Certificates and Money Market accounts as well as demand deposits? Is there a similar restriction on gifts associated with loans/lines of credit?
06/09/2003
We have accumulated many accounts that are "no address" accounts. These have accumulated due to the customer not keeping us notified of a new or forwarding address. At one time, most of the accounts were service charged over a period of time and closed on their own due to a zero balance. Since that time, we have merged our regular checking product into a product that doesn't have a monthly service fee, therefore, most of the accounts are no longer service charged and would stay at their current balance (63% of them have less than $50 on deposit) until the funds would be escheated. NOW... the question....we are exploring the opportunity of implementing a service fee for "no current address" accounts. Our initial discussion with compliance was that we could implement that fee to all future "no address accounts" but not to the existing ones since we couldn't truly "Notify" them of the adverse change. I want to wholeheartedly disagree with that since we did disclose at the time the customer opened the account that it was their responsibility to notify us of any address changes.
01/20/2003
We are an advertising agency doing some research for a client of ours, who happens to be a local bank. We are in the creative process, planning a good advertisement and incentive to get the community to open checking accounts with us. We are looking to offer a specific dollar amount to anyone who opens an account. But we know there are some restrictions against that according to Regulation Z. What I need to know is how much can a bank offer as a premium to get someone to open an account? Is there a limit, or specific ratio/number?