If you use a vendor that provides credit scores from all 3 bureaus and you only use the score/reasons from one bureau for the denial, do you use that specific bureau's name and address or the actual vendor that supplied the report for your adverse action notice?
What is your view on retention of the physical deposit hold notices to meet Reg CC retention requirements? We recently converted our core system and have the opportunity to electronically record data used to populate deposit hold notices rather than retaining the physical forms.The data will be in the form of a report rather than a customer view of the notice. Parameters are set in the system for hold types, hold days, and makes consideration for multiple hold scenarios such as large deposit hold for amount over $5,000, two day availability for $4,800, and next day for $200.There is also a required field for facts to support reasonable cause holds when confidential information is selected.
I would like to know what (if any) parameters surround banks giving bonuses to customers. I am familiar with the typical $10 refer a friend program but I am looking at amounts exceeding $10,000 on more than one occasion. The bonus or referral fee (I’m not sure how it is categorized) is paid based on how many people sign up for pre-paid cards on a monthly basis. I was able to find this article (noted below) but I think it misses the mark regarding what I’m looking for. The reason why I saved this article was
the bonus payments I’m referring to do not fall within the guidelines of numbers 1-3. “Now let’s look specifically at Regulation Q and what it has to say about paying a bonus on an account. In fact, §217.101 is specifically titled “Premiums on Deposits.” (a) Section 19(i) of the Federal Reserve Act and 217.3 of Regulation Q prohibits a member bank from paying interest on a demand deposit. Premiums, whether in the form of merchandise, credit, or cash, given by a member bank to a depositor will be regarded as an advertising or promotional expense rather than a payment of interest if: (1) The premium is given to a depositor only at the time of the opening of a new account or an addition to an existing account; (2) No more than two premiums per account are given within a 12–month period; and (3) The value of the premium or, in the case, of articles of merchandise, the total cost (including taxes, shipping, warehousing, packaging, and handling costs) does not exceed $10 for deposits of less than $5,000 or $20 for deposits of $5,000 or more. “
In regards to the check box options on an adverse action notice, as a commercial lender, I would like to add “Length of time in business is too short” as we do deny credit to many newly established companies (per our credit policy). So my question is this: Can I create my own reason or is there a specific set of reasons that I need to adhere to? Where does ‘length of time in business too short’ or verbiage to that effect fit on an adverse action notice?
Will our bank be responsible for reimbursing the sender if a foreign remittance is credited to the wrong person’s account because the sender provided the wrong routing information?
Customers frequently drop off loan applications along with deposits, loan payments, etc. at our branches. Loan Ops is located in our home office several miles away. Is there a problem with sending these along at the end of the week?
How do we mitigate risk on a third party payment processor?
What is the most common way that banks record or log complaints and inquiries to have available when the examiners come in looking to see what we have?
We have a customer cashing her daughter's payroll checks off of her account with our bank. Her daughter has a charge-off with our bank. Can we refuse to cash these checks due to the charged-off account? All other bank check cashing policies are being followed.
We had an insurance check deposited in April made payable to two account holders AND the title company. In May, the Insurance company bank asked via fax for a return of the funds due to improper endorsement. We requested that the bank return the check so that we could release funds to them through our clearing company but they are insisting that they can't and want us to send a check directly to them. It has been a few months and we are in a deadlock while the member's funds remain on hold.