Most Popular Compliance Content
Collection Communication for Demand Deposit Accts.
04/22/2018
Collection communication for demand deposit accounts (i.e., overdraft notices, NSF notices, request for payment, etc) - are we allowed to send such notices if we are aware of an active bankruptcy case? What if we are not made aware of the bankruptcy case?
New CDD Rule: Identify Authorized Signers-Business
04/22/2018
With the new expectations of the CDD Rule that goes into effect next month, are we required to identify authorized signers on business and organization accounts?
Removing Joint Owner from Safe Deposit Box
04/22/2018
I'm not sure what this falls under, but I have a question about safe deposit boxes. I have always been told that if you have a safe deposit box joint with someone else and you wanted to remove their name from the box then you could do so. Is this not something you can do? I know you cannot remove a joint owner from a checking, savings, etc.
Score in Chex System for Adverse Action Deposit
04/22/2018
Do you provide a score, contained in a Chex Systems report, in an adverse action notice for deposit accounts? I'm working on our deposit audit and am confused by the definition of a credit score. Section 615 of FCRA refers you to 609 (f)(2)(A) for this definition: (A) CREDIT SCORE.--The term "credit score"-- (i) means a numerical value or a categorization derived from a statistical tool or modeling system used by a person who makes or arranges a loan to predict the likelihood of certain credit behaviors, including default (and the numerical value or the categorization derived from such analysis may also be referred to as a "risk predictor" or "risk score"); and (ii) does not include-- (I) any mortgage score or rating of an automated underwriting system that considers one or more factors in addition to credit information, including the loan to value ratio, the amount of down payment, or the financial assets of a consumer; or (II) any other elements of the underwriting process or underwriting decision. COMPLIANCE FCRA, Credit Score, Credit report
Joint Acct. w/ PODs- "Trust Under Agreements"
04/22/2018
A client wishes to open a joint account and designate 3 POD's; 2 are "Trust Under Agreements" and the 3rd is an actual person. First, I don't see the 2 beneficiaries as conforming to the FDIC definition of a beneficiary. I have concerns with that. Furthermore, is it permissible and what are the ramifications in allowing it? Or should this be handled in a bank with trust services?