When advertising a CD special on a rate sheet that will be provided to customers, and the ad only indicates the CD special product name with a statement that says, "ask us how to open your CD special," and nothing else, but the CD special has conditions and limitations that the regular CD accounts do not, should a bank disclose on the rate sheet what those conditions and limits are that differ from the regular CD products that are also listed on the rate sheet? There is a fully disclosed addendum for the special that covers the Reg DD disclosure requirements. However, this will only be provided if the special is opened by the customer. My concern is that if the customer only requests the rate sheet and doesn't open the account the customer will not receive the addendum or the full scope of the special on the rate sheet and this may be a little misleading if the customer comes back at a later date to open the special and they find out there are conditions to be met on the product.
Do we have to close NRA interest-bearing accounts if we do not have FTIN?
If my bank qualifies for, and opts into, the Community Bank Leverage Ratio (CBLR) Framework for our March 31, 2020, Call Report, can we opt OUT of the Framework at a later date?
Should we obtain new W-8BEN on every nonresident alien customer?
During account setup, we would like for the CSR to setup the mobile app information on the core system. The customer will be able to use the app without having to go into mobile banking and completing a few steps. Should the customer sign any type of disclosure allowing us to do this? Is there anywhere I can find this information in a regulation?