Vendor Guru Q&A - Compliance

Latest Compliance - Dormant Accounts Topics

Document Management and Dormant Accounts

02/14/2021

How can document management software reduce risk on dormant accounts?

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

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?

Handling Reg E claims on older transactions.

07/25/2021

If an EFT claim is made long after the statement is sent showing the transaction, the rules of investigation don't apply. So why do we investigate any of these claims?

Compliance Info on Paper Checks

07/25/2021

I was wondering if you could point me in the right direction as to where to find more information on compliance for paper checks? Whenever I place a stop payment on a paper check, there's a disclosure that says "this request will expire in 6 months in order to comply with regulatory requirements." For the customers who ask for a more in-depth answer, what can I tell them?

Reg E Fraud- EFT Claim for Cash App

07/25/2021

During a review of the account, we noticed several transactions to Cash App, to the same people from last December and one in January. These were NOT disputed. Should we inquire about these transactions? If so, could we start our calculation from the statement date (plus 60 days) from the statement with the first unauthorized transaction? Does it make a difference that the December, the May and June transactions were on different cards? (The customer has had multiple cards.)

ACH Return for Unauthorized Debit

07/25/2021

Can a customer initiate an ACH Return for unauthorized debit from a closed bank account?

Reg E Telephone Transfers/Transactions

07/25/2021

I have a question about telephone transfers. The telephone transfers we perform are for the customer who calls the bank and requests the teller to withdraw from one account and transfer funds to another account. We currently have a custom form that a customer signs to perform ongoing telephone transfers and we keep this on file authorizing the bank to perform these transactions. We would like to discontinue using this form. Is this old form necessary and is it even a compliance requirement under Electronic Fund Transfer Act? We currently document on the transaction ticket "Telephone Transfer per Customer request". Any advice or information would be greatly appreciated.

Latest Compliance - Dormant Accounts Topics

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