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" sufficient? Does Reg DD indicate the need to specify the term "cleared or completed" when referring to posted?
What is demonstrable consent and can we do that with new account disclosures we email the new customer?
We are a de novo bank and our BSA officer mentioned that it was "recommended" by FDIC regulators that banks need to check their correspondent banks on OFAC anytime they send or receive a wire from them. To me this seems pointless and quite excessive. We send/receive wires through PCBB and I can't see us needing to check OFAC lists for their name daily. Is this really necessary?
For the Reg CC RDC indemnity, it states; "(2) A bank described in paragraph (f)(1) of this section shall indemnify, as set forth in § 229.34(i), a depositary bank that accepts the original check for deposit for losses incurred by that depositary bank if the loss is due to the check having already been paid." We have a customer which is a business offering check cashing and it makes deposits via remote deposit capture. I am confused over the liability and timing of paper vs. electronic deposits, duplicate items and will restrictive endorsements influence liability?
A ninety-seven year old widowed customer was brought in by one of his sons to change the register on his account. Our customer's wife had passed and he removed her and added the son as beneficiary to his now sole ownership account. Six months later the same son was granted Conservatorship over his father and changed the register to "Estate of..." Should we leave the beneficiary on an Estate of Conservatorship account?