We have a customer who is POD on her fathers account, but she is telling us that she does not want the money. Is there a time limit on how long a POD account can sit out there even if we have contact with the POD? What recourse does the bank have on distributing the money to the appropriate POD? I know that FDIC insurance lapses 6 months after the death of the owner.
Is FDIC coverage changing this year?
Have you heard of the obvious error rule? The FDIC has recently completed a compliance exam and mentioned the obvious error rule in relation to the APR calculation on open-end credit.
Should the words POD appear on a customer's bank account statement if it appears on the customers account agreement?
If the Bank has a customer testimonial poster inside a branch that is not product specific but states the bank's name and a statement using the customer's words how the bank helped the customer's needs does that need to state Member FDIC?
Can there be two trusts with two separate EINs as owners on one account?
We are going to offer a DDA tiered rate paying 2.75% on the first $10,000 if qualifications are met (10 debit card transactions - 1 direct deposit or debit - access Internet banking once during the monthly cycle),.25% on balances over $10,000 if qualifications are met and .05% on all balances if qualifications are not met. It has a $100 to open minimum but interest will be paid on all positive balances. How do I disclose the APY? On the top tier do I use the $100 (min to open) to disclose the amt used to obtain the APY or can I use $1? On the middle tier - do I have to take into consideration the first $10,000 earned the higher rate?
Our bank has numerous branches, a handful of insurance agencies, and also five office locations for non-deposit investment products. I am relatively new to the bank but not to compliance. In reviewing the bank's advertisements, there may periodically be an ad that talks about deposit products that are offered, "checking and savings accounts" and in addition may even mention "mortgages." In the same ad it may mention that we also offer insurance and investments. In the ad that refers to all these types of products, it will not state "Member FDIC" or "Equal Housing Lender" due to including the statement about insurance and investments. I am really having a hard time finding this acceptable even though one FDIC examiner has "OK'd" this type of combined ad in the past. Shouldn't the ad clearly segregate the bank's products and services from the non-deposit investments (with the required disclaimers) and insurance products? I have referred to Part 328 - Advertising of Membership of 12 U.S.C. 1818(a) etc., I just need to know if I am understanding the requirements correctly.
We recently had an FDIC compliance exam and were criticized for gathering information on some home equity refinanced loans. We had been told in the past that if it was a refi, we should get the info...we are not a HMDA reporting bank. This examiner said that according to Regulation B it depended on what the principal percentage of what the refi was used for...either purchase money or HE. We checked with several non-HMDA banks and they are doing it like us. The examiner said we could question it, but this was his determination. Any help?
Can you give a free gift valued over $25 to customers with a Health Savings Account? The account is coded as a checking account.