If credit is denied because of issues related to only one applicant, for example a charge-off, can we disclose that reason to both applicants, and do both applicants get an Adverse Action Notice?
Has there been a case where a lender tried so hard to assist minority applicants that it had a fair lending issue with majority applicants?
If we have a situation where your name goes into the "hat" if your customer or a referral you made opens an account or deposits $50,000 new funds into the bank, when the prescribed period is over a drawing will be made for a prize (example $500 gift card), this would be a lottery, right?
Can we advertise a drawing on social media only?
What is the most common way that banks record or log complaints and inquiries to have available when the examiners come in looking to see what we have?
We want to promote debit card usage and management wants to have a monthly drawing for a $25 gift card. I think that this is not permitted since it would not allow non-customers to enter and bank customers with debit cards are the only ones who can win - am I correct?
We have seen other banks do this in our area, so management thinks it is just fine.
Is CAN-SPAM consumer protection and limited to consumers?
If we offered a HELOC teaser rate in the past, does that APR need to be reflected in the Application Disclosure Historical Index Table? The Official Interpretation of 1026.40(d)(12)(x) 4. Amount of discount or premium. This uses the word "may."
Can email notifications be sent for abandoned property? My understanding is that this is subject to what each state may require depending on the address the account holder is located. Some states require a written notice to be mailed. So if we meet E-SIGN requirements would that supersede state requirements? Would CAN-SPAM Act also need to be considered as not being in violation since it talks about "notification of a change in the recipient's standing or status"? I'm thinking this Act is more related for purposes of commercial electronic mail.
Does CAN-SPAM apply to those emails sent by platform employees to let their preferred customers know of new rates, etc.?