I am new to the compliance function so I apologize if this does not make sense. My question addresses Reg DD and a CD interest payment date vs. maturity date. Here is an example: a CD term is 6 months and interest is paid every 30 days. Since there are more/less than 30 days in some months the interest payment date does coincide with the maturity date, so there are generally a few days between these dates. I am unable to find anything in the TISA reg about this. How and when is interest paid in relation to the maturity of the CD?
When orally quoting a deposit rates over the phone, if the APY is 3.00%, does the the employee need to state the APY as 3.00% or can they say the APY as 3%? Likewise if the APY was 3.50% do they need to say the APY is 3.50% or can they say the APY is 3.5%?
What are the mandatory (required) training courses for employees to take annually?
I have a question about a CD special. The bank's rate sheet lists a 12-month CD as well as a 12-month CD Special that has a considerably higher interest rate/APY than the regular base CD. The bank also allows negotiation and will pay a higher rate to keep business. For the "special" and any other negotiated rate, the rate is only in effect for the initial term and at maturity will renew at the 12-month non-special rate. I'm looking at 1030.5; Comment 5(a)(1)-1 and I am thinking that advance notice would be required since the terms are changing upon the occurrence of an event (renewal). There is nothing on the TIS disclosing that the initial term is a promotional period and that the CD will renew at the lower non-special rate in effect. Am I thinking about this correctly?
We are a small community bank that maintains strong connections with our customer base. From time to time, a customer we know well brings us a check for deposit that's accompanied by a seemingly legitimate backstory. But the appearance of the check, based on our experience leads us to believe that the check may not be paid because not ALL of the boxes can be checked to rule out that that it's a fraudulent check. Knowing our customers we tend to give them the benefit of the doubt by accepting the check for deposit and placing a Reasonable Cause hold for 4-5 days. Our acceptance of the check is done in good faith that our customer's story is legitimate and our Reasonable Cause hold is done as a means of ensuring that our customer doesn't end up on the wrong side of a scam. I have read several opinions which state the ONLY course of action that's entirely compliant is to refuse to accept the check for deposit. Most opinions are that we simply cannot place a hold for Reasonable Cause to Doubt Collectibility in this situation. Even after completing due diligence on the check and the facts offered by the customer, by refusing a check where some facts indicate authenticity and others indicate potential fraud, why would we not be allowed to try in good faith to accept the check, while protecting our customer from potential loss by way of a Reasonable Cause hold? After all, the teller has formed a "well grounded belief that the check MIGHT not be paid," but is also acting in good faith on behalf--and in favor--of our customer. We are all advocates for our customers, and simply refusing to accept a check for deposit simply because we couldn't check off EVERY box that it isn't a fraudulent check, seems counterintuitive to the consumer-favoring language of Reg CC.