(1) If a bank offers new checking customers $10 for opening the account and an additional $25 if the customer signs up for Direct Deposit, is it true that we can avoid issuing a 1099 because the $10 is within Reg Q guidelines and the $25 is tied to a service, and not the opening of the account? (2) Is it true that Reg Q does not apply if a minimum balance is required in order for a new checking account customer to receive a specific cash premium? For example: The promo offer is that if you open a new checking account with a deposit of $2,500 or more, the bank will give you a $50 cash deposit/premium (payable on a specific date following the promotion as long as the account is active and in good standing) and a 1099 is issued. If so, can the offer be extended to both interest bearing and non-interest bearing checking accounts?
We have the Regulation E Short error resolution notice on the reverse of our statement paper. We do not send an annual notice to our passbook account holders. Passbooks may receive a Direct deposit. Are we required to send a separate annual notice to these customers? Our auditors say we are. I thought passbooks were exempt from the periodic statement requirement and that the short Reg. E notice on the statement could be used in lieu of an annual notice.
We just read the California court ruling regarding offsetting OD fees against Social Security benefits (B of A case). How do I find out if other states' -- in particular Wyoming's -- rules are regarding the same issue?
A customer of ours has had an account with our bank for over 50 years; this customer and spouse are both in their 70s and they refuse to have direct deposit for their social security checks. The 3rd of every month, they come in and cash their checks. Are we REQUIRED to give them their full amount (about $2,300) even though they have a $100 balance in their account? That is our requirement to maintain a savings account. They are great customers, but refuse to open a checking account or deposit any of the monthly social security checks. We think they must be stuffing their mattresses! HELP!
We are looking at offering a stored value card that will allow our business customers to direct deposit payroll to this card, in a master account, rather than issuing a check or direct depositing to an individual's account. The business issues the card to the employee and they use the card just like a debit card. What disclosures are needed for this product and would these be issued to the business only, since they are our customer, or would it need to be issued to the business and each employee that receives a card?
We have been informed that required records to be retained for BSA compliance including credit slips for loan payments, money orders, etc must show the amount of any currency involved.Is this, in fact, a requirement of BSA rules?
Does the periodic statement exception <a href="http://www.bankersonline.com/regs/205/2059.html">205.9(c)(1)(i)</a> for passbook accounts apply to telephone banking transfers or to ATM activity on a passbook savings account? We are adding ATM access and Telephone banking and were wondering if the passbooks were exempt from the periodic statement requirement. If not, it would probably be easier for us to only offer these services with a statement savings account.
We offer an interest checking account to individuals 55 and over. To promote this account we will be offering a $10.00 bonus to anyone who opens a new account. In addition, anyone who signs up for direct deposit will be paid an additional $20.00. Is this $20.00 considered a bonus under Reg DD, since it is only being paid if the customer signs up for direct deposit and does it trigger the bonus disclosure requirements for advertising? The Compliance Department is saying the bonus disclosure is applicable because the customer has the possibility of receiving $30.00.