Is a bank permitted to advertise for an affiliated investment company on the bank's website, such as by offering a link to access the investment company services? If yes, what type of disclosure do we need to provide to the customer?
Marketing has created a list of services that the bank offers (checking, savings, loans, investments, etc.) in a creative design. The window cling will only be visible inside the bank. The bank name, member FDIC, Equal Housing Lender and Not, Not, May are not included on the window cling.
Can we omit these disclosures since it is in the lobby and the list is generic?
Are there any rules against an individual / consumer having a repurchase agreement?
Is a series 7 required to sign up people on oil/gas lease?
If a customer has 50% of their total sum in investment products and on occasion uses their NOW or DDA account for personal payments, would regulation DD apply? It is the banks policy not to open consumer accounts. We are Private Banking, and open accounts mainly for investment purposes but do offer for convenience,other types of bank accounts. For these instances we also require the customer to sign a certification letter that states that accounts are being maintained for facilitating the acquisition of investments and only incidentally personal, family or household purposes, which in no event will involve use of more than 50% of the account balance.
Our bank has numerous branches, a handful of insurance agencies, and also five office locations for non-deposit investment products. I am relatively new to the bank but not to compliance. In reviewing the bank's advertisements, there may periodically be an ad that talks about deposit products that are offered, "checking and savings accounts" and in addition may even mention "mortgages." In the same ad it may mention that we also offer insurance and investments. In the ad that refers to all these types of products, it will not state "Member FDIC" or "Equal Housing Lender" due to including the statement about insurance and investments. I am really having a hard time finding this acceptable even though one FDIC examiner has "OK'd" this type of combined ad in the past. Shouldn't the ad clearly segregate the bank's products and services from the non-deposit investments (with the required disclaimers) and insurance products? I have referred to Part 328 - Advertising of Membership of 12 U.S.C. 1818(a) etc., I just need to know if I am understanding the requirements correctly.
I have a commercial loan with two residential properties, one primary and one rental but the customer owns out right but the is not purchasing, refinancing or using any part of the loan for home improvements. Is this loan HMDA reportable? The purpose is for commercial investments into another business.
Under 12 CFR 230 (Regulation DD), it discloses Truth in Savings disclosure requirements. I am wondering if an IRA is considered a time deposit account, and if a TIS disclosure is required for an IRA.
Is RESPA applicable to an individual who purchases a one to four family residential property for investment (business) purposes?
I have a consumer who owns multiple 1 to 4 family rental properties. He is interested in obtaining loan on one of the rental properties for the purpose of making business investments which may include the purchase of additional investments properties. Would this be a business purpose loan and exempt from RESPA?