We have a large LLC Customer who has a Now account. It was supposed to be changed when noticed at our last Compliance exam. I hate to bother this very large account, with a low interest rate and move him into a higher rate Money Market Account. What are the options and penalties?
What is the minimum number of days you must charge on a CD penalty?
What are the bank policies that need board approval and how frequently?
I'm looking for someone who remembers when MMDAs and NOW Accounts were legalized for banks. Seems like MMDAs were first, the fall of some year, then NOW Accounts were authorized at 5.5% for commercial banks on January 5th of the next year. Was that 1980-1981? I'm trying to educate some younger bankers on Reg D and the history of reserves, NOW Accounts, etc.
Do you have to state the interest rate and APY on a monthly bank statement for interest-bearing accounts?
We have a customer who wants us to comply with the Servicemembers Civil Relief Act. I understand we have to drop the interest rate on the loan to 6% when called to active duty. They have sent us a copy of their orders but, from what I can tell they are just a change of duty order. They are enlisted in the Navy, and they feel we should make the rate retroactive to the date they entered the service, are they correct?
This question is concerning the truth in savings disclosures at account openings. One of the affiliate banks I work with omitted, in error, the interest rate schedule section of the TISA new account disclosure from the time of conversion as a new affiliate of a bank holding company, until recently when it was discovered as an omission. The TISA has since been revised to include the interest rate schedule for the new accounts, however, new account holders for the past 7 months did not receive rate information at the time of new account opening for NOW, Savings and MMAs. Should the bank send out the revised account disclosures to all of the account holders who did not receive interest information at account opening for the last 7 months, or is the fact that these customers have since received periodic statements sufficient?
On a promissory note is the size of the print on the note required to be a certain size? If so, where would I find the Reg on this?
Failures in lending compliance can cost as much as $14,000,000. That's the amount one lender will have to pay for unfair lending practices and compliance failures.
Historically when a customer has called to request interest rates, we have always stated the interest rate immediately followed by the yield. Recently it came up that we may want to state the yield first. I know that the yield must be stated but is there anything that says specifically that the APY has to come first or second? If so, could you tell me where I could find that information?