Which regulation has a clause governing the color of ink a consumer must use when writing or endorsing a check?
I am the Electronic Banking Specialist for [Bank Name Withheld]. We are having a debate among ourselves and our Legal Department regarding whether or not check imaging is covered by Reg E. One opinion has to do with whether the check image is truncated or not; another has to do with the intent for imaging, whether as a tool for the merchant to recover funds on a returned item, or as a bank tool to pacify clients who want their checks back. I would appreciate any input that you might offer as you have a more industry-wide view available, as well as experience in compliance and Reg E issues.
Our bank is getting ready to start imaging loan documents. Where can I get some information about what documents we should keep originals of and not rely on images?
Question: We image all our loan documents. I am looking for guidance on what can be destroyed after it is imaged.
It's countdown time to Check 21 in our industry, and I'm observing a phenomena I never seen since I entered the banking industry 34 years ago.
Authority for Imaging
by Mary Beth Guard
The banking industry has been so caught up with 326, 314, and CIP of the PATRIOT Act that some really big legislation almost managed to get by without a whole lot of press or notice.
I am looking for a "free" booklet or publication that gives guidelines for Record Retention Policies. My bank is small and I am trying to implement some written policy/procedures for a retention policy. My background is from a large bank that had written manuals for guidance. With the latest technologies for imaging documents I hope to eliminate unnecessary paper and the need for so much storage.
I understand that it is not a violation of ECOA to require an ID and photocopy it at loan closing. However, also I understood that taking a photocopy of a picture ID for a loan file is considered "collecting monitoring information" which according to Section 202.13 of Reg B is allowed only for credit secured by a dwelling. Aren't we setting ourselves up for "discrimination in lending" by keeping pictures of those we approve and decline in loan files?
Are we allowed to photocopy treasury checks?