Vendor Guru Q&A - Compliance

Latest Compliance - Federal Reserve Topics

When Is Reg CC Going to Change?

06/23/2014

When is Reg CC going to change? I went to a seminar and the instructor stated June 1st. I have not heard anything else about this.

Reg F Requirements on Correspondent Bank Capital

06/17/2013

I am trying to get updated copies of our correspondent banks capital ratios, in accordance with the requirements under Regulation F. I have been able to get all of them but one from the Federal Reserve Bank. Do I really need one from them?

Notice for Stopping Checks for Money Market Acct.

05/27/2013

If you stop offering the ability to write checks from your money market account, what disclosures or notice must you give to your customers?

Reg for Change on Who can have Now Account

09/10/2012

The change on who can have a NOW account (Businesses). When was the change and in what Reg is the change found?

New Reg CC-How Long Hold New Account Checks?

08/13/2012

Under the new Reg CC rules, how long can we hold New Account checks?

Reg E Periodic Statements and EFT

07/30/2012

Is there something in writing from the Federal Reserve and/or the CFPB that supports the comment in this<a href="http://www.bankersonline.com/operations/guru2012/gurus_op011612a.html "> Q and A</a> on Reg E periodic statement requirements? The Iowa Bankers Association, our compliance liaison from the Federal Reserve, and all other sources I can find seem to disagree with this point of view. They say the IF an account CAN be accessed by an EFT, regardless of whether it actually is, that at a minimum quarterly statements have to be provided (and also for each month when an EFT occurs).

Final Rules for Dodd-Frank Act Section 1073

06/18/2012

I see that Dodd-Frank Act Section 1073 has an effective date of January 2012. Have we seen any final rules to comply with yet?

Negative Finance Charge and Calculating APR

03/12/2012

In talking with The Federal Reserve Board, it was determined that a negative finance charge is not a charge but a credit and should not be used in calculating the APR. We have found a blog on <a href="http://www.bankersonline.com/lending/guru2010/gurus_ldng102510a.html">BankersOnline website</a> that states differently. Where can we find the information to back up the answer that was given on this blog?

Where to Find REF Repeal of Reg Q (Demand Deposit)

03/05/2012

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?

Credit Score Notice w/ AAN (Denying Deposit Accts)

01/23/2012

In lieu of the risk-based pricing notice, we use the credit score exception notice. It automatically prints every time we pull a credit bureau report. I understand the purpose of the risk-based pricing is for lending, but we also use the credit bureau report to determine if we will open an account. Is it permissible to give this credit score notice with an AAN when denying deposit accounts?

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Fed Issues Supervisory Letter on BETR (Bank Exams Tailored to Risk)

The Federal Reserve issued a Supervisory Letter (SR 19-9) describing its enhanced process for scoping safety and soundness exams of regional community banks (generally, banks with less than $100 bi

Credit Reports for Joint Applicants

Question: I have a Reg B compliance question.

Misleading Collection Scripts Cost Financial Institution $28.5 Million

10/18/2020

In its $28.5 million settlement with Navy Federal Credit Union (NFCU), the Consumer Financial Protection Bureau (CFPB) stated that NFCU's collection letters contained material misrepresentations – or unfair or deceptive abusive acts or practices – that were likely to mislead consumers; how did NFCU's templates violate UDAAP?

Add Bank Fees Paid in Cash to CTR?

10/18/2020

Should bank fees (Cashier Check purchase fee of $6.00) paid by the customer in cash, be added to their current CTR? If so, would the bank be the benefactor and the customer the transactor?

How to Complete a CTR for Local Diocese

10/18/2020

A question came up during a recent audit in regards to how a CTR would be completed for a local Diocese. This particular Diocese has a few different churches using the same EIN. Our system recognizes large currency transactions that we compare to see if a CTR was completed. My question is, would a CTR be filed on that specific church when deposits of cash are over $10k, or on the Diocese?

Max Escrow Cushion

10/18/2020

How do we know when a cushion is allowed?

Option 1: CFPB Debt Collection Plan Doesn't Spare Community Banks

10/11/2020

In May 2019, the CFPB issued a Notice of Proposed Rulemaking (NPRM) for the Fair Debt Collection Practices Act (FDCPA); how has this rule updated the antiquated FDCPA? the NPRM will likely have a dramatic impact on collection practices for debt collectors.

Latest Compliance - Federal Reserve Topics

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