06/06/2005
Do internet transfers from a Money Market account count as in-house transfers as far as transfer limitations are concerned? We are currently making a large depositor physically make these transfers to meet regs.
05/23/2005
We are thinking about allowing customer to complete a loan application on the Internet and submit it back to the bank via Internet. Must we provide the appropriate disclosures electronically through the Internet? If so what about the new federal consumer credit score disclosure? We will have to run credit before we can get that to the applicant.
05/23/2005
I have a few questions. We have an on-line web application with our company and the question has come up as it refers to compliance. We are looking for confirmation as to when an application from a web application is considered an actual application: <ul><li>Is it when the borrower submits the minimum amount of information or a low loan amount (our site refers loans to our officer when the amount is below $50,000) and no credit is pulled, but we have the saved information in the site that can be pulled and given to loan officers to call the borrower?<li>Is it when the borrower submits for credit and underwriting and they receive an approval or denial from the web site?<li>Is it when the loan officer contacts the borrower after either of the above and the loan officer and borrower determine this to be an actual loan application?</li></ul>
05/01/2005
These days, a good place to gaze into the crystal ball and foretell the future of the payment process is a consumer electronics show.
04/18/2005
What are the record retention requirements for Internet Banking and Bill Pay? I have been searching for information, but have not been able to find anything.
04/04/2005
When opening an account on the internet, what disclosures should be given to the applicant at time of application? This would be for checking, money market and CDs only.
03/28/2005
02/07/2005
What are the best practices when offering internet banking to CORPORATE accounts? And further, if individuals on these corporate accounts also hold consumer accounts with us, can we allow them to transfer between the corporation and their personal accounts via internet banking?
01/31/2005
I've read your articles on Reg. E Disclousres on the Web. But we are taking applications for Internet banking via the Web. Do we still need a Reg. E Disclosure and what should we be sure to include and watch for?
01/31/2005
If your bank offers bill payment over the Internet banking service, does the Reg E disclosure have to state more than the fees your bank can impose, plus the customer's "agreement to pay any additional reasonable charges not covered by the (internet banking) agreement" (for example, if the payment is NSF and the merchant charges an NSF fee electronically as well)? Can that NSF fee then be charged against the customer's account, or are there additional notices which would need to be provided?