Most Popular Compliance Content
Accounting Teams at Banks
02/20/2022
What are the basic duties of bank accounting teams?
Returning POS transfers
02/20/2022
Is there a possibility that POS transactions can be returned the same way ACH transactions are?
Periodic Statement Revisions Allowed?
02/20/2022
Our current periodic deposit account statements show all the required parts for compliance required at 1030.6(a). We show the APY Earned based on the General Formula from Appendix A-2.2.A. If we decide to remove only the “Interest Rate” reflected on all periodic deposit account statements going forward, could we be out of compliance with 1030.6(a)? Also, if we continue to leave the interest rate on the periodic statements, would it be an UDAAP issue, potentially causing confusion for consumers to see a different interest rate on periodic statements than what is on their TISA, due to fluctuations on deposits and debits?
Reg E Claims and Chargebacks
02/20/2022
Regarding 12 C.F.R. §1005.11 - Am I correct in understanding that consumer liability MAY be applied in the tiers but is not automatically applied to all of those claims in which it may apply? For example, lets say we have a $74.00 transaction in question and the claim is that it is unauthorized. We determine that it is a fraudulent transaction. If we hold the consumer liable for $50 (granted they told us about it within 2 days of discovery) that means that we could not file a dispute (according to our vendor's procedure) because we would have to file for the full $74 and upon winning that dispute we would then profit from the dispute process as we are only "out" $24 at this point but would have an excess of $50 and no account to apply it to except Other Liabilities and we cannot offset our debit card losses with it. Let's say that we just hold the consumer liable for $50 and write off the $24 as a loss, which would make no sense to me either seeing as how our chargeback process is only $12 a claim. Also, we have Visa debit cards so in saying that, if the transaction was not run through the Visa network, but say run through STAR, would our consumers not have the Visa Zero Liability protection since the card used has a Visa brand?
Incentive payments and 1099s
02/13/2022
Our bank would like to give current customers $25 cash to refer a friend. We have been advised that those clients must then receive a 1099 at year end for the "gift." I've seen other banks do this successfully so are they all issuing a 1099?