12/13/2010
Is a bank required to have FDIC signs in each drive through lane or is one on the window enough?
10/18/2010
Under the extended FDIC TLGP program, are IOLTA accounts restricted to an interest rate of twenty-five basis points or less? These accounts are addressed separately from other NOW accounts in all the material I have received.
10/18/2010
We qualify loan applicants based on gross income. Our credit officer says that tax free income from SSI or VA Disability is the gross income and shouldn't be grossed up. I say the income is net and should be. Who's right? If we don't gross tax SSI up, are we discriminating?
10/04/2010
Are we required by the FDIC to show our letters of credit on our balance sheet? We carry ours as a participation, but because it is unbooked, it doesn't show on our balance sheet. At all of the other FDIC banks I've worked for, we've been required to show our letters of credit on our balance sheet.
09/06/2010
On our consumer notes we have the credit insurance clause that the customer signs when signing the note, and on the note is also the Federal Sale of Insurance Disclosure that the customer signs if he/she decides to get the Credit Life or Disability Insurance. When printing the documents, it prints the Federal Credit Application Insurance Disclosure. All this is in our software from Arta Lending. If all this information is on the Arta Note, do we have to print and have the customer sign the disclosure also?
08/23/2010
I need to find out what the required elements are of a bank audit committee charter. We are a community bank supervised by the FDIC.
07/05/2010
Extension of credit made to insiders must be on substantially the same terms and conditions as comparable credit extensions to comparable borrowers. How would our federal regulator, FDIC, be able to determine this when performing an exam? We want to ensure that this is not being done or ever will be.
03/22/2010
I heard from a colleague that the FDIC is citing banks under Regulation CC (Section 229.16(c)(2)(ii)) for mailing case-by-case hold notices for deposits made in person by a customer. Apparently this was caught by the examiners in banks where their procedures require that large dollar checks deposited into customer accounts be placed in a bin for later review/hold determination by an Ops manager or where there is a secondary review of all hold notices prior to mailing. Purportedly, the FDIC has taken the stance that a case-by-case notice may only be mailed to the customer when the transaction was not done in person and that any references in Regulation CC and the commentary about mailing a notice refers only to those specific deposits which are not done in-person. This is not the way we or our compliance auditors have looked at this in the past, and we are curious to know how your group views this. What say you?
01/18/2010
We're marketing HSAs. Marketing considers this a checking account and only needs Member FDIC. Compliance says we need insurance disclaimers (not, not, may). Who is right?
01/04/2010
I am reviewing our compliance due to the recent reminder from FDIC via FIL-66-2009 regarding Disclosures at ATMs. Are we required to post notice on both the outside face of the physical ATM and on the screen? If so, must these notices also disclose the fee amount?