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.

Threshold for Regulation Z Coverage (Non-RE Loans)

02/16/2020

Should non-RE loans that exceed the dollar threshold for Regulation Z coverage still be considered consumer loans as far as coding and reporting? We have a difference of opinion. One side believes the Reg Z exemption essentially changes the loan into a commercial loan in every way. The other thinks that the disclosures in the documentation is where the exemption is primarily seen and the loan should be coded and reported exactly like any other loan of its type that is under the threshold. Any clarification would be appreciated.

Latest Compliance - Federal Reserve Topics

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