In our TIS disclosure we disclose our overdraft fee only, but not in the order that we pay overdraft transactions. We are considering changing to largest items paid first in hopes of increasing fee income. What, if any, disclosures do we need?
We are looking for ways to increase fee income and raising our VSI premium was mentioned. Can we charge a few dollars over the actual premium and still be in compliance? Reg Z was the first thing that came to mind. Please let me know what you think.
We refer customers to an outside vendor for Merchant Services. The company we deal with has created an incentive program for these referrals. They have submitted one of our employees a check in the amount of $50 for a referral that resulted in a sale. I have read and understand the RESPA implications in regards to referrals in the mortgage lending area, but what about the Deposit side of the bank? Do we allow the employee to accept the check?
There is a common denominator to the leading issues on the compliance front burner. The issues are all point generated by concerns that consumers may not be treated fairly.
In Advisory Letter 2004-10, the Comptroller of the Currency advises national banks on credit card marketing and account management practices that may be unfair or deceptive.
From the beginning, the regulatory agencies have said it loud and clear: they don't like bounce protection.
When it comes to designing marketing campaigns, the marketing staff tends to view compliance with some skepticism - if not outright hostility.
When the lifeguard says it's not safe to go into the water, it is generally a good idea to stay out - and dry.
Regulatory burden is real. And it inhibits what a business can do. Sometimes banks bring it on themselves. This is certainly the case with overdraft protection.
Congress has asked the Federal Reserve to study the disclosure of fees imposed by account-holding institutions on debit cards issued to consumers.