If we offer a discount coupon from a local business to a consumer opening a checking account, is that considered a bonus under Truth in Savings?
How will the new FDCPA rules impact first-person collections?
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 I get a promise to pay two days from now on Wednesday and they don’t show, can I call Thursday morning?
Under the proposal can we use social media to contact a debtor?
1026.53 - Payment Allocation reads pretty clear - payments in excess of minimum payment must be made to the balance with the highest APR and then descending until the payment is exhausted.
But "balance" is not clearly defined. One could argue there could be two different balances. Cycle to date balances (in current cycle) or cycled balances (prior cycle)
For example; suppose a card holders billing cycle is the 1st – 31st with a payment due date of the 21st. The account has the following balances that rolled over from prior cycles;
$10,000 BT Promo at 0%
$225 Purchase at 11.99%
On the 21st the card holder makes their minimum payment of $25 which is applied to interest, fees and balances on the account in accordance with Regulation Z.
On 23rd the card holder makes a $500 purchase at 11.99% and a $2000 cash advance at 12.99%.
On the 28th the card holder makes an additional payment to the account of $3000. Should the additional (excess) $3000 payment be in the following order;
$2000 to the cash advance balance at 12.99%.
$700 the purchase balance at 11.99%
$300 to the BT Promo at 0%
Do not apply any of the excess payment to the transactions that occurred in the same cycle.
Alternatively, the payment is applied to the balance in the prior cycle:
$200 to the purchase balance at 11.99%
$2800 to the BT Promo balance at 0%
and nothing to the cash advance balance
What is correct?
The bank has used "replacement" to replace a private label card with a VISA open loop card. Some of the cardholders have not activated their cards, some probably because they threw away the envelope without opening their mail. The bank is considering placing a block on the cards, pending activation from the customer so that the customer can still activate rather
than reapply. The other option is to send a letter to activate the account within a stated time, otherwise the account will be closed. The consumer would need to apply again for a card. IMO, the second choice is a better customer experience in the absence of some foundational regulation to assert one position or the other.
What might happen if we don't have a system to track complaint resolutions?
If a consumer has a rate on a specific credit card and voluntarily chooses to apply for a higher rate card product with the same institution, does the institution have to protect the lower balance at the lower rate or because the consumer asked for the new higher rate product can the entire balance be moved to the higher interest rate? So say a non rewards card and the consumer wants a rewards card and they agree to moving the existing balance over to new rewards product.
Do we have to disclose the actual MAPR to all borrowers?