We are an intermediate small bank for purposes of CRA. Is this program appropriate for us?
What is a bank document imaging policy?
When a former customer who left owing us money shows up at the teller window to cash a check written to him by one of our account holders, can we seize the proceeds of the check to go toward what we’re owed?
The opt-in requirements under 1005.17(b)(1) state that a bank "shall not assess a fee or charge on a consumer's account for paying an ATM or one-time card transaction." Does the "one-time" term mean that we cannot charge a fee on the first transaction of two or more being paid and then we can charge a fee on the second when the consumer has not opted-in? For example, if a customer has not opted-in and an ATM causes an overdraft into the consumers account and then two EFTs are received and paid on the same day as the ATM for processing, can we charge or not an overdraft fee for any of the EFTs? On subsequent days, if the account is overdrawn by EFTs, can a fee for overdraft be charged?
We are working with a consumer mortgage customer and their escrow account for their insurance and taxes. They have a hardship case due to advanced age and declining health issues, and we are looking at ways to keep their payments as low as possible. I know that it is required by regulation to keep payment reserves in the escrow account, but if we reduce or waive those requirements could we still be cited for not following the letter of the regulation?