04/02/2007
Our internal auditor has asked for our "current ACH Origination Agreements that clearly states that the originator is liable for complying with AFAC requirements." Where would we obtain this document? How can we monitor compliance from all the ACH originators?
02/12/2007
I am the Electronic Banking Specialist for [Bank Name Withheld]. We are having a debate among ourselves and our Legal Department regarding whether or not check imaging is covered by Reg E. One opinion has to do with whether the check image is truncated or not; another has to do with the intent for imaging, whether as a tool for the merchant to recover funds on a returned item, or as a bank tool to pacify clients who want their checks back. I would appreciate any input that you might offer as you have a more industry-wide view available, as well as experience in compliance and Reg E issues.
01/22/2007
Is it stated anywhere how often you have to provide deposit account statements for checking/savings?
10/02/2006
According to Reg D, when counting transactions for excess activity on money market accounts, would a check converted to an ACH transaction by the recipient count as a check (3 per cycle) or an electronic transfer (6 per month)?
01/16/2006
When conducting an annual ACH audit, is the compliance officer or internal auditor more responsible for the audit? As the auditor, I can see that ACH can involve Reg E, Reg CC, and Check 21 at the minimum. Since our compliance officer is also concerned with protecting the consumer, doesn't this make it important that the compliance officer completes the audit?
04/04/2005
Do we need to scan our ACH Origination files for matches to the OFAC list? If so where does it state so.
01/24/2005
11/15/2004
This is a Regulation D question regarding savings accounts. We are looking at moving the balances of all savings accounts that have ACH debits currently set up, as well as all accounts that have an ATM or debit card, into a separate general ledger and classifying those accounts as "Transaction Accounts" for call report purposes. These accounts would not be closed or transferred to another type of account. This would leave the savings accounts as they are now. This would be an internal move only of the balances to a transaction account that the customer would not be aware of. The accounts would continue to earn interest and the customer would continue to pay the bank's excessive W/D fees. Would this eliminate the necessity to notify customers of limitation requirements on existing accounts? Could this make monitoring of any of the savings accounts possibly unnecessary? Could you continue to pay interest on this type of account? Or would this be considered a total violation of Reg. D?
10/11/2004
09/06/2004
What regulation applies to ACH and to the charges of an ACH transaction?