Vendor Guru Q&A - Compliance

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Latest Compliance - Dormant Accounts Topics

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

Is it mandatory for a bank to send notices when an account status changes from active to dormant? We 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?

Problems for the Future

01/01/2000

In planning your compliance program strategies for the future - or at least the next several years - there are issues that we can see coming.

Guidance on Timeline for Issuing Debit Card

02/17/2019

Is there language in any regulation or even industry guidance on the timeline for issuing a debit card once a customer has requested one? I suspect one of my bank's branches is waiting 90 days to issue every single card. At minimum, I want to streamline the process so that cards are issued on the same schedule across all branches, and just want to be able to defend whatever timeline we use.

Opening Business Account-Tax ID & Name Change

02/17/2019

We have a customer trying to open a business account. He has provided us with a 2017 Tax Return, which gives us the Tax ID under which the business is operating. I typed this Tax ID number into the Texas Comptroller of Public Accounts website and got a hit, showing that the business is in good standing. However, the name that was listed has been changed since the Comptroller website was updated (surprising since the 2017 Tax Return reflects this change). The company is not currently operating and, therefore, the individual opening the account does not have access to documentation of the name change for the Secretary of State office. The question is, do we have what we need to open the account? The tax return and Comptroller website verify that the Tax ID number is valid and in Good Standing, but they disagree on the business name.

Regs/Requirements for Time Deposit Accounts

02/17/2019

Our company is wanting to offer Time Deposit accounts. I have read Reg. DD and I see that Time Deposits have certain restrictions on withdrawal periods and penalties but I don't think they are much different than Certificate of Deposits and Auto Save IRA CD's. Basically if we adhere to TISA requirements are we okay to offer these or should I be looking into any other regs or requirements?

Trust for a Revocable Trust-Check Acct. Style

02/17/2019

Can a checking account be styled In Trust for a Revocable Trust?

3 items for Reg E liability

02/10/2019

A customer had a charge out of his account six months ago. That’s old and means he has unlimited liability so we don’t have to investigate it. Is that right?

Latest Compliance - Dormant Accounts Topics

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