Our FI is planning on using Promontory to offer broker deposits to consumers.
I have thought that Reg DD, section 1030.4 thru 1030.6 (Account
Disclosures) apply, however the Agreement and periodic statement don't specifically
address by Reg DD the required elements. For example, their Agreement states
accrued interest will be credited "at least once each month" vs. a specific
frequency, and it does not reference if accrued interest will be paid or not
paid if the account is closed, and refers to the APYE as "Statement Period
We have just received communication from the vendor and they are telling us
that "A Relationship Institution is a “deposit broker” for purposes of
TISA and, as such, is subject only to the advertisement provisions of Reg
DD." But they don't even spell out at least once Annual Percentage Yield.
Is our FI required to meet all the requirements of Reg DD as if the consumer
were opening one or our MMAs?
Is there an FDIC requirement that the "Member FDIC" logo be on all our pages and link to the FDIC website?
We include the EHL logo on our website where we offer home loans. We also use Twitter and Facebook, but do not use it there because it is on our site. Are we OK?
Is the term “Equal Housing Lender” on our website sufficient or should we actually have the “Dog House” logo?
Do weblinking rules apply if a business has a link to us, and are we required to monitor this?
We currently keep both electronic copies and paper copies of every change made on our website. This is time-consuming to maintain. How critical is it to keep hard copies of our work, and what questions should we be asking ourselves to potentially reduce or eliminate unnecessary paper trails?
What is demonstrable consent and can we do that with new account disclosures we email the new customer?
Our Chamber of Commerce is hosting a cash & prize giveaway to encourage people to shop local during the holidays. As a member of the Chamber of Commerce, the bank has been asked to pass out tickets as entries to win. Each business has a limited number of tickets. Employees of the bank are not allowed to obtain any tickets from the bank, but can from other businesses participating. My question is, can we offer multiple tickets as incentives for our customers to use other services we offer?
Examples would be:
1) A customer comes in to make a deposit= 1 ticket. If they sign up for online banking while here we will offer an additional ticket.
2) A non customer comes in to cash a check= 1 ticket. If they open an account with us we will offer additional tickets.
3) A customer asks about a home loan= 1 ticket. If they qualify, they can earn additional tickets. If they decide to finance with us more tickets.
We often have lobby posters advertising products, services, benefits like trips on a discounted price and others things on display so staff can answer questions on these and to promote these items. Do they require the general FDIC advertising statement>
If we price HELOCs based on the applicant's credit score and loan to value ratio, so some borrowers get a lower rate than other borrowers, can we disclose the lower rate in our advertisement, or do we need to disclose both rates? Do we also need to specify the criteria for receiving the lower rate?