If we price HELOCs based on the applicant's credit score and loan to value ratio, so some borrowers get a lower rate than other borrowers, can we disclose the lower rate in our advertisement, or do we need to disclose both rates? Do we also need to specify the criteria for receiving the lower rate?
Is following the standard Regs, B, Z, DD and fair housing going to ensure advertising compliance?
If my bank qualifies for, and opts into, the Community Bank Leverage Ratio (CBLR) Framework for our March 31, 2020, Call Report, can we opt OUT of the Framework at a later date?
Have the October 2019 proposed changes for the Community Bank Leverage Ratio (CBLR) Framework been finalized?
We have a “spin the wheel” promotion. To spin, a customer must donate $1 that the bank donates to a charity. All the prize amounts on the wheel are more than $1 therefore all customers will get more than they donate. The amount won is then sent to the customer via our e-wallet app. We set a certain number of spins and it is done on a first-come-first-served basis.
Will opting-in to the Community Bank Leverage Ratio (CBLR) Framework change how my bank's assessment rate is calculated?
Has COVID-19 had any impact on the call report?
What is the most common way that banks record or log complaints and inquiries to have available when the examiners come in looking to see what we have?
A customer had a charge out of his account six months ago. That’s old and means he has unlimited liability so we don’t have to investigate it. Is that right?
What is our obligation under Reg E if a spouse on an account wants to file disputes for charges incurred by the other spouse on the account?