04/07/2008
Since we cannot require employees to accept e-statements for their deposit accounts, we are trying to develop incentives that will highly encourage them to sign up for the e-delivery. Presently, employees are not charged a service charge for their accounts. Can we change this policy for existing and future employees, so they will receive an account free of charge if they use e-statements? Otherwise they will be charged the normal service charge incurred by customers without violating regulations, thus start assessing a service charge on all existing employee accounts unless they sign up for e-delivery.
01/07/2008
My question is regarding the required deposit statement on the TIL. If my bank states to a customer that if they open a deposit account, they will receive a lower rate, then does the TIL have to have the statement that the APR does not reflect the effect of the deposit?
11/12/2007
I have a very technical GLBA question. It is my understanding that if all employees of the bank are required to have deposit accounts then they are also considered a customer under GLBA. If there happened to be a breach of employee nonpublic information through the HR department, say the payroll vendor was compromised and all employees' social security numbers were released, would this not be considered a breach under GLBA and notification required to the affected customers (employees) along with notice to our regulators? Is it possible since the breach occurred through HR department and was of employees' nonpublic information that it is not defined as a breach under GLBA?
10/15/2007
Believe it or not, we do not have free checking yet. We have realized the need to put together a free checking account - not specific to age - and we are wondering what are the can do's, have to do's, and the don't do's are with establishing such an account. Your thoughts are appreciated.
10/08/2007
Do the FACTA provisions only apply to consumer loans? If not, what other type of loans are affected by the FACTA?
03/12/2007
I am a new compliance officer and in the process of developing a procedure pertaining to ID theft. How do some institutions handle holds on accounts for customers that are a victim of identity theft (FACT ACT)? I know that we could close the deposit account that is affected by the ID theft and reopen a new one, but what about the other deposit accounts the customer has with our institution?
02/19/2007
I need some advice regarding Reg D. Our bank would like to offer our business customers a checking account that could sweep excess funds into another account nightly in order to earn interest. Our competition is offering an "Automated Funds Manager Account" where they sweep funds into an investment fund, such as repurchase agreements. How can we offer our business customers a checking account that would offer a "sweep" feature and avoid the six transfer limitation? Do we have to sweep funds into outside investment accounts or can we sweep into one of our internal products?
07/24/2006
I am unable to convince our bank president that telephone transfers and internet transfers are counted in the six that may occur each month on a savings account. I have downloaded the Reg D chart and the law, but he is still not convinced. Can you tell me where I might find more to show him in a clear manner?
03/20/2006
Are we required to give our Reg CC disclosure for all types of deposit accounts opened? (Time deposits, savings, etc.)
03/20/2006
For Reg DD, what types of products does the minimum dollar amount need to be stated to earn interest?