Can the temporary unlimited coverage where all funds in non interest bearing transaction accounts are insured in full by the FDIC be located in an FDIC insurance tab on a Bank's website?
My question pertains to the FDPA (Flood Disaster Protection Act) regarding the notification requirements to the borrower when a loan is modified. Is the bank required to provide the Notice of Special Flood Hazard and Availability of Federal Disaster Relief Assistance to the borrower when the loan is being modified? The modification was to lower the current rate on the existing loan. I have read the FDIC section 339.9 requirements, the 2009 Interagency Q and A's, and the Mandatory Purchase of Flood Insurance Guidelines (2007) and all are mute to the notice requirements pertaining to loan modifications.
Do you have a sample copy of the due demand clause for Reg O? We have FDIC examinations and run a good bank, but they say we should have an executive officer sign the due demand clause.
What are the legal requirements for a bank to open a savings account for an individual customer? From what I understand, banks usually require (1) a signature card and (2) the following identity information: name, address, date of birth and identification number. I don't need any clarification on the identity requirements for Know Your Customer compliance. I am looking for more clarification on the requirements for the signature card. Is the signature card required by law to open a bank deposit account? If so, what is the law and what is the legal definition of a signature card (e.g. the required elements for a signature card)?
REF: Repeal of Reg Q allowing interest on demand deposit account. Where can I find this change in the regulation since the new CFPB has taken over? It was previously in FDIC Part 329 Section 329.1 (b)...Where can I find the new wording?
I am trying to find a format to address a requirement from recent FDIC Examiners and have searched your website (and others) without finding what I need. Our BSA Risk Assessment “does not contain detail analysis of data obtained during the identification stage in order to assess risk.” Can you help me find a format for this?
Do we have to/should we have our clients sign/acknowledge that they received a copy our our new Privacy Notice that went into effect 2010? My question stems from a recent FDIC exam.
A bank charges a $20 credit report fee for consumer real estate loans, but the fee is actually less. Should the amount that is in excess of the actual cost be considered a finance charge for Reg Z purposes? I realize there is a huge RESPA issue in this practice as well.
We have an upcoming FDIC Compliance Exam. In the pre-exam questioning, I was asked if we provide a "Conforming Loan Payment Notice". I thought this was just for the credit card payments but was told that this also involves "payments on residences". I have searched for some type of guidance and have only found information that pertains to credit cards and helocs. In "googling" the topic, I have found several banks that have the disclosure on their website. This is telling me that I have certainly missed something. Could you give me some guidance or somewhere to look further?
The FDIC's Overdraft Supervisory Guidance says that institutions are expected to have procedures and policies in place by July 1, 2011. I am trying to understand if a fee is charged on the sixth occurrence, but waived three weeks later. Does an institution need to adjust the occurrence count back to five? Does waiving of the fee need to occur at the time it is charged for the overdraft?