Vendor Guru Q&A - Compliance

Latest Compliance - Interest Topics

Loan with a right of rescission

09/20/2020

I have a closed-end consumer 1-4 family refinance with new money being loaned. This loan has a right of rescission. Am I to collect interest on the refi loan to the date of the loan or the day it comes out of rescission?

CD Product with All Interest Paid Up Front

08/25/2019

Our bank is exploring the idea of a new CD product in which all the interest is paid up front on the date of initial deposit. In the case of early withdrawal, are we able to deduct the penalty from the principal since there would be no interest accruing during the CD term?

Add Higher Balance Tiers On Investment Savings

07/14/2019

Our private banking area is requesting to add two higher balance tiers on an investment savings account. There is no regulation or rule that would hinder this correct? The only thing I can see is if we are not offering this to other bank customers, but only to these high end customers.

CD Interest Paid Monthly Change to Compound

01/13/2019

If a customer with a 4 year CD with interest paid monthly, after 6 months, decides to have it compound annually, what would be the next date for interest to be paid? The opening date was 1-1-2016.

Reg E- De Minimis Rule-Interest Amount on Claim?

12/23/2018

Is there a de minimis rule under Reg E denoting at what amount interest needs to be provided on a claim and with provisional credit? We have scenarios where the customer is owed a penny or two and it isn't worth the cost of the entry.

Can Commercial DDAs Be Interest-Bearing?

11/25/2018

Can commercial DDAs be interest- bearing?

Rate Sheet Required for Interest Bearing Accounts?

01/14/2018

On interest bearing accounts, must a bank whether in person or via online e-disclosures provide a rate sheet to their clients or is this discretionary?

Reg D Interest Bearing Checking Account

06/07/2015

With regard to Reg. D, I was always under the impression that a single member LLC could have an interest bearing checking account. Can you add anything to that?

Simple Interest Method for LOCs

05/25/2015

We have several consumer LOCs where the note states average daily balance is calculated using the simple interest method. Our system charged interest on interest. What steps do we take to correct?

Periodic Statement for Transfer of Interest COD

01/19/2015

Is it necessary to provide a customer with a periodic statement for a monthly transfer of interest from a certificate of deposit to one of their accounts at another financial institution?

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Action Training: What Is An APR?

Oh my. The head of the Consumer Financial Protection Bureau cannot explain what an APR is.

Escrowing during Construction

10/25/2020

Can we collect property taxes during construction based on the completed value of the home?

Reg E Question About Credit Card Fraud

10/25/2020

When a cardholder has a fraud alert on their card and they tell the fraud center that the transactions are NOT fraud, the fraud center reopens the card. Now the customer has roughly 10 or more charges from the same company that she just said were not fraud. Now she is claiming that they are all fraud. (including the original charges) What do we do?

Chamber of Commerce Cash & Prize Giveaway

10/25/2020

Our Chamber of Commerce is hosting a cash & prize giveaway to encourage people to shop local during the holidays. As a member of the Chamber of Commerce, the bank has been asked to pass out tickets as entries to win. Each business has a limited number of tickets. Employees of the bank are not allowed to obtain any tickets from the bank, but can from other businesses participating. My question is, can we offer multiple tickets as incentives for our customers to use other services we offer? Examples would be: 1) A customer comes in to make a deposit= 1 ticket. If they sign up for online banking while here we will offer an additional ticket. 2) A non customer comes in to cash a check= 1 ticket. If they open an account with us we will offer additional tickets. 3) A customer asks about a home loan= 1 ticket. If they qualify, they can earn additional tickets. If they decide to finance with us more tickets.

Add Bank Fees Paid in Cash to CTR?

10/18/2020

Should bank fees (Cashier Check purchase fee of $6.00) paid by the customer in cash, be added to their current CTR? If so, would the bank be the benefactor and the customer the transactor?

How to Complete a CTR for Local Diocese

10/18/2020

A question came up during a recent audit in regards to how a CTR would be completed for a local Diocese. This particular Diocese has a few different churches using the same EIN. Our system recognizes large currency transactions that we compare to see if a CTR was completed. My question is, would a CTR be filed on that specific church when deposits of cash are over $10k, or on the Diocese?

Latest Compliance - Interest Topics

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