Vendor Guru Q&A - Compliance

Latest Compliance - Federal Reserve Topics

Fraudulent Cashier's Check- Late Return

10/10/2021

We received a call from a credit union on 9-1-21 informing us that a cashier's check on them was fraudulent. We sent that check out on 8-5-21. We waited 10 business days to give the customer credit. (8-20-21) The customer has spent more than half the funds but I placed a hold on the remaining amount. Do credit unions not return through the Fed like banks? They sent us an Indemnification Agreement to sign and send the funds back. Could this be considered a Late Return? Help!

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?

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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.

New Escrow on Existing Loan

10/17/2021

We had a customer ask to start a voluntary escrow account on an existing loan. Do we need a new agreement?

Military Identification Card

10/17/2021

If a customer presents a military identification card and has no other form of ID, it is my understanding is you cannot make a copy of Military ID's. What other forms can be used? This person does not drive and has no transportation to get to the DMV. He does have an expired TX DL but that is all.

Risks for Online Account Opening (CIP)

10/17/2021

How are smaller banks, say in the $200M asset size, managing compliance risk when diving into online account opening? I'm very concerned about CIP-CDD-EDD. I cannot fathom never obtaining a wet signature or seeing a check prior to accepting a deposit. Also, asking the CDD-EDD questions online is completely different than in person regarding getting a feel for the customer. Do most banks also open new accounts online for businesses, trusts, estates, etc? Is there a vetted software company that is preferred for this endeavor?

List of Board Policies (Regs/Acts)

10/17/2021

I was wondering if there is a list of board policies that financial institutions are required to have (regulation/acts) along with how often they should be reviewed by the board?

New Escrow on Existing Loan

10/17/2021

We had a customer ask to start a voluntary escrow account on an existing loan. Do we need a new agreement?

Latest Compliance - Federal Reserve Topics

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