Should non-RE loans that exceed the dollar threshold for Regulation Z coverage still be considered consumer loans as far as coding and reporting?
We have a difference of opinion. One side believes the Reg Z exemption essentially changes the loan into a commercial loan in every way. The other thinks that the disclosures in the documentation is where the exemption is primarily seen and the loan should be coded and reported exactly like any other loan of its type that is under the threshold. Any clarification would be appreciated.
We have a customer that we suspect may have several fraudulent checks written against her account. How long does she have if they are fraudulent,
to sign the forms that they are fraud?
This is about an advertisement that offers a bonus to a customer and one of the conditions to be met in order to qualify for the bonus is having a set
number of debit transactions posted to the customer's account within a specific period of time. When disclosing this qualification in the ad for
the customer, should it be specified as "posted and cleared to your account" to be more clear and conspicuous or is the language "posted to your account"
Does Reg DD indicate the need to specify the term "cleared or completed"
when referring to posted?
On interest bearing accounts, must a bank whether in person or via online e-disclosures provide a rate sheet to their clients or is this discretionary?
We have a customer who signed & opted into ODP when he first opened the account in September. After the 45-day qualification period, it was found that his account was eligible for ODP so we activated the ODP on his account. A teller at his branch, however, took a request from him to revoke ODP on his account in late November. This was not relayed to the appropriate staff and the change did not get made on his account. His TV bill, which is an authorized monthly payment, came through on his account as a POS debit while he was already a couple dollars negative. It should've been declined due to NSF and him previously revoking ODP. We've since made the appropriate changes on his account to revoke ODP on his account and we've reversed all the fees he shouldn't have been charged, but the customer is saying he is not going to pay for it, and that the bank is responsible for it.
My question is - is the bank responsible for it?
I have been instructed to lead a project around compliance ramifications if negative interest rates were to occur in the US. With regard to deposit accounts, would all TISA and other initial disclosures need to be updated to reflect this change. Since the change in terms would negatively affect our customers. This would be quite an undertaking as we have 10 member banks. Would all of our advertisements have to be re-disclosed? Any feedback is greatly appreciated.
Is a Notice Regarding Overdraft Fees disclosure required to be posted on an ATM? A question was recently asked about required ATM signage (https://www.bankersonline.com/qa/required-signage-atm) however I did not see mention of this Notice. Could this be a CA specific notice or one that may have been required in the past? The notice reads “If you do not have sufficient funds in your account for the withdrawal amount requested,completing the transaction may result in overdraft fees if you have given us prior permission to complete such transaction….”
On our Funds Availability sign, we have our main branch city and state. Should each sign have its location on it or do we even have to have a city and state on the signs?
I have received a call from a compliance sales group that says the first $100 of the held amount changes effective 7/21/2011 to $200.00 I cannot find this regulation change. Does anyone know about this? If so where can I find the change in the regulation.
As a follow-up to your question regarding a customer unwilling to file a police report - does that section of Reg E also include checks? It seems to speak about electronic transfers, but what about giving the customer their money back when the unauthorized transactions are stolen and forged checks? Are we required to reimburse if they will not file a police report?