06/13/2011
Who pays for Visa's zero liability? Is it the banks/credit unions or is it Visa? Recently, my company (a credit union) took a 45k hit in one month due to Visa's zero liability. We have seen a ton of claims due to PlayStation 3's security issue. I always thought that visa picked up the bill.
07/12/2010
If there are outstanding miscellaneous fees due (attorney fees, etc.) can we take the funds out of a customer's escrow account?
03/29/2010
We have a mortgage preapproval program as defined by 203.2 - a preapproval program as a request for preapproval for a home purchase loan is an application under paragraph b(1) of this section if the request is reviewed under a program in which the financial institution, after a comprehensive analysis of the creditworthiness of the applicant, issues a written commitment to the applicant valid for the designated period of time to extend a home purchase loan up to a specified amount. Section 3500.2 defines an application as the submission of a borrower's financial information in anticipation of credit decision relating to a federally related mortgage loan, which shall include the borrower's name, the borrower's monthly income, the borrower's social security number to obtain a credit report, the property address; an estimate of the value of the property, the mortgage loan amount sought, and any other info deemed necessary by the loan originator. The six items to trigger a GFE requirement are property address, loan amount, monthly income, estimated value, borrower name, and social security. Since a property address is not known on a preapproval, is a GFE required? What if we request verification of income? Does that not trigger a GFE on a preapproval even if the property address is unknown?
02/15/2010
When is an application subject to RESPA, requiring disclosures to be sent? Is it when you have taken the initial 1003 by phone or email, or is it when you have a signed 1003 by customer and have verified income and assets, etc?
12/14/2009
What are the error resolution and disclosure requirements for pre-paid gift cards? Is the financial institution required to notify its customer base of the gift cards prior to them being offered for sale?
10/20/2008
We charge a fee of $25 for selling cashier's checks and a person buys a cashier's check for $9,990 in cash and pays the fee in cash, should we file a CTR? If a customer wants to cash a check for $10,010 and asks the teller to deduct the $25 fee from the check, should a CTR be filed?
05/26/2008
I had a customer rescind in the three day time period. What needs to be done with all the documents?
09/10/2007
Reg Z does not specifically address "filing fees." Is it necessary for the filing fees entered in the Fed box to match the filing fees found on either the itemization or the HUD? Is there a difference in the answer between open-end and closed-end transactions?
10/16/2006
It is my understanding we can not use social security and VA direct deposits to offset overdrafts and fees. We have a customer ($2.00 in a passbook) who owes us for $800 in returned check items (2) that she cashed. She will be bringing in her social security check to cash. Can we take that to offset her returned deposited check items?
08/21/2006
I know you can't "stop payment" on a cashier's check but you can "refuse to pay" if the remitter or payee asserts a claim in writing because the check is lost, destroyed or stolen? Can we charge the customer our Stop Payment Fee of $20.00 for this service or would we have to change our Schedule of Fees to include a "Refusal to Pay" fee before we could charge for this service?