10/10/2011
According to Reg P, a financial institution is not to give out any account information, including account balances and account status. We regularly get calls from other financial institutions, companies like Comdata, and individuals asking if a check or ACH will clear. Are we allowed to give out that information under Reg. P?
12/13/2010
Is anyone aware of any compliance/regulation issues that would prevent our bank form instituting a customer referral program? Basically, we are thinking about paying customers $10 for every customer that they refer to us.
11/08/2010
Is accidentally exposing the incorrect check images to customers via online banking considered a reportable event for information security and privacy purposes? I am thinking that it is, since users can save the images to their desktop or other device. The check images are not images of the online banking user's checks, but of other customers' checks that contain bank account number, name, address and a signature.
05/10/2010
Many of our commercial clients originate ACH files and some transactions get returned for insufficient funds, etc. When an ACH transaction is returned to us, we charge it back to the client’s account, much like we do for returned checks. We have a couple of clients who have asked for an individual ID to appear on our ACH Return Notices, along with appearing on the transaction itself (though DDA and/or Online Banking history), and appearing on the DDA statement. We have a procedure in place that stops this information from printing on the original ACH transaction for consumer clients. Many of them complained, since this field may contain social security numbers. There is no regulation on what has to appear in this field. It may contain a SS number, but may also contain other information. I have seen a mix of things in this field ranging from a blank field, to a person’s name, to a string of numbers and letters that do not mean anything to me. Basically, we hide this field from consumers due to their complaints. The situation I am asking about is slightly different, but I would still like to confirm with you that there are no regulatory or privacy issues. For the custom we are getting ready to ask for, it will show the information that is in this field, it will show it on the actual return notice, it will print it on the statement, and will also appear through DDA and OLB history. The difference here though is that the client who sees this information on his return notice and on hus statement is the same client who populated that field, so I do not think it will be an issue, since it is information that the client provided to us originally, and that he already has access to it, but I wanted to double check before we get too far down this road.
03/15/2010
When granting access to a safe deposit box, bank policy requires use of a private coupon room, but many customers want to access their boxes quickly, in the vault itself. Is there an industry best practice, either for or against, granting access to a safe deposit box while inside the vault?
10/26/2009
A hold was placed on a deposited check that the bank received by mail. The bank was unable to reach the customer by phone, but mailed the hold notification the same day. The customer contacted the bank by email a week later, upset that he wasn't notified at the time the hold was placed. He stated he received the notification three days after the deposit was made. Would it have been acceptable to notify the customer by email if the message was not detailed, but stated something to the effect "Please contact (bank employee) at (bank name) concerning a hold."?
07/26/2009
Is a pop up box required to let customers know that they are leaving our bank’s website and linking to our affiliate’s websites?
05/04/2009
How can the bank benefit from the BITS Shared Assessment Program?
03/30/2009
Does the Federal Privacy Act prohibit a bank from verifying funds for another bank if a customer presents a check drawn on a customer's account?
03/16/2009
How are banks impacted by the FACT Act?