Latest Compliance - Dormant Accounts Topics

Email Notifications Sent for Abandoned Property?

02/23/2020

Can email notifications be sent for abandoned property? My understanding is that this is subject to what each state may require depending on the address the account holder is located. Some states require a written notice to be mailed. So if we meet E-SIGN requirements would that supersede state requirements? Would CAN-SPAM Act also need to be considered as not being in violation since it talks about "notification of a change in the recipient's standing or status"? I'm thinking this Act is more related for purposes of commercial electronic mail.

Debit Card and Online Banking Inactivity Fees

01/31/2016

Our Retail Division is getting very creative in coming up with fees that we have not charged in the past. I understand that dormant/inactivity fees are defined at the State level and are allowed on accounts advertised as "free." Would the same hold true for debit card inactivity and/or online banking inactivity fees? Would these fees be allowed on "free" accounts if properly disclosed? I have the same question for return mail fees.

Notification When Acct. Changes to Dormant?

10/18/2015

I​​s it mandatory for a bank to send notices when an account status changes from active to dormant? ​W​e send notices when the account status changes from dormant to active but not the other way.

Dormant Status for Health Savings Accounts

08/16/2015

Can a Health Savings Account be put into dormant status? Can the account then be closed? If we do close the account after the statute of time, if there are any monies available how are those funds to be distributed and to whom?

Laws On Changing Monthly Fee On Dormant Accounts

09/01/2014

I have two questions in regards to dormant accounts. We consider accounts to be dormant after 24 months of inactivity. 1.Are there varying state laws when it comes to the ability to charge a monthly fee on dormant accounts? 2.If we have a customer that has multiple accounts and they are like titled, same address, can we transfer the funds to an associated active bank account if we disclose this to our clients via some manner of electronic communication?

How Long Until Do Something W/Dormant Accounts?

05/06/2013

Information on dormant accounts. Loan is Bankrupt and small amount in a DDA account. How long till you can do something with dormant accounts?

Dealing with Dormant Accounts

08/09/2010

We have several dormant accounts with less than one dollar in them. Should we charge each account a regular monthly service charge which would be equal to the balance, then close it out, or should we send everyone a money order for the amount? That way, if it comes back to us, we'll escheat it and all others we get back, to the state.

Dormant Accounts - Privacy Notices Required?

10/01/2007

Is it a requirement to send privacy notices to dormant DDA accounts?

Advance Notice To Raise Fees?

02/10/2003

It we increase our fees on stop payments, dormant accounts, and add a daily overdraft fee, do we need to send our existing customers advance notification of the fee increases?

Regulatory Requirements For Dormant Accounts

07/15/2002

Where in the regs do you go to find more information on dormant accounts? Example: can you close a dormant or inactive account with a very small balance, and what fees can you charge on a dormant or inactive account?