Vendor Guru Q&A - Compliance

Latest Compliance - E-Sign Topics

Electronically Signed Form-Unauthorized DC/ATM

07/19/2020

Can the bank accept an electronically signed form from a customer for unauthorized debit card or ATM activity?

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.

Easier Way to Sign Up for E-Statements: In-person

04/21/2019

We would like to create an easier way for our consumers to sign up for E-Statements. What are the requirements, compliance wise for this? Currently, our customers need to log into their online banking, view a PDF disclosure that generates a "code", and customer then has to type in code and agree to terms and conditions. Compliance wise- can consumers just sign the disclosure/consent in person at lobby?

How do you track changes to web pages?

02/11/2018

We currently keep electronic copies and paper copies of every change made on our website. How critical is it to keep these?

Can we offer NOW accounts to businesses?

05/07/2017

Since Reg Q was eliminated, Marketing wants to start offering NOW accounts to business customers. Can we do that?

Communicating Change to Business Mobile Customers

12/12/2015

We need to communicate a change to our Business Mobile Banking customers. Is it permissible to send these customers (approx. 450 relationships) a text message to their cell phones with a link to the product change description without getting their express consent?

Requirements for Mailing eStatements

05/26/2014

If a business or personal account holder does not look at their checking account e-statement, what are the bank's requirements in mailing the statement?

Reg B: Allowed to Email Copy of Appraisal?

05/12/2014

Reg B - appraisals - can we email a copy of the appraisal to the Borrowers as long as it is secured and we get a read receipt for the email? How long after this do we need to wait to close the loan?

Order Appraisal on Same Day if Have Receipt?

04/22/2013

If I email the disclosures to the client and they acknowledge receipt, can I order the appraisal on the same day?

Turning Paper Statement Option Off?

04/08/2013

Currently, when a customer signs up for estatements we still send a paper statement. The paper statement turns off when they open their first estatement. Are we required to do this or can we turn the paper statement option off completely when they sign up for estatements?

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COMPLIANCE Q & A: E-sign and e-statements for consumers and businesses

Question: We are looking at the regulation around E-Sign and how it pertains to consumers and businesses that wish to enroll and accept e-statements.

E-Sign Disclosures

Question: Do E-Sign disclosure requirements apply to faxes? Should E-Sign disclosures be provided on a customer level or an account level?

Misleading Collection Scripts Cost Financial Institution $28.5 Million

10/18/2020

In its $28.5 million settlement with Navy Federal Credit Union (NFCU), the Consumer Financial Protection Bureau (CFPB) stated that NFCU's collection letters contained material misrepresentations – or unfair or deceptive abusive acts or practices – that were likely to mislead consumers; how did NFCU's templates violate UDAAP?

Add Bank Fees Paid in Cash to CTR?

10/18/2020

Should bank fees (Cashier Check purchase fee of $6.00) paid by the customer in cash, be added to their current CTR? If so, would the bank be the benefactor and the customer the transactor?

How to Complete a CTR for Local Diocese

10/18/2020

A question came up during a recent audit in regards to how a CTR would be completed for a local Diocese. This particular Diocese has a few different churches using the same EIN. Our system recognizes large currency transactions that we compare to see if a CTR was completed. My question is, would a CTR be filed on that specific church when deposits of cash are over $10k, or on the Diocese?

Max Escrow Cushion

10/18/2020

How do we know when a cushion is allowed?

Option 1: CFPB Debt Collection Plan Doesn't Spare Community Banks

10/11/2020

In May 2019, the CFPB issued a Notice of Proposed Rulemaking (NPRM) for the Fair Debt Collection Practices Act (FDCPA); how has this rule updated the antiquated FDCPA? the NPRM will likely have a dramatic impact on collection practices for debt collectors.

Latest Compliance - E-Sign Topics

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