I have been trying to find what the requirements are for giving bonuses to open a new account. There are advertisements everywhere of cash offerings, freebies, or giveaways. We’re still stuck on the value of offer cannot exceed $10, however we see TV ads offering $300 to open an account. What compliance issues do we need to address if our offerings go beyond $10? As an example, April is Teach your Children to save month. Marketing has come up with a campaign that if you come by and get a piggy bank and bring it back full of coin with your child and use it to open an account, the bank will also deposit $10 into that new account, or it could be an existing account.
For account opening, my bank requires a separate application, signature card, and Uniform Single-Party or Multi-Party Account Selection Notice. Is there a regulation/law/code that requires all of these to match? While auditing, I noticed POD selection and information missing from an application; however, the beneficiary has been named [properly] on the selection notice. Do I need to have the customer complete a new application?
Is a Corporate Banking Resolutions on a bank's letterhead which is completed and certified by the Board Secretary with the corporate seal affixed, sufficient to memorialize a resolution taken by a company's board of directors regarding actions related to a banking relationship such as appointing a new board secretary or adding and deleting signers?
Our attorney posed a question to me that he received from a customer. He wants to know under what circumstance do we change our deposit disclosures? I told him when we have a regulatory change or a policy/product/service charge or other change. Also, I said if the change is adverse to the deposit customer we have to notify them in a certain number of days according the change requirement or regulatory requirement. If the change is to the customer's benefit, we may or may not do a mailing and just post it on the website, social media or on the their statement. Our attorney wants to know the general rules for account agreement changes, when to change them and where it appears regarding the adverse change or customer benefit change. Any thoughts?
Should the owner of a sole proprietor business account cash checks made payable to him personally using the business account?