When a customer violates Reg D for the third time, we take away whatever was abused; such as internet transfers, ACH etc. Can we give what we took away back to the customer or is it gone for good, or do we not take away something and just close the account? I'm not sure what is a best practice.
We have a customer wanting to open an Professional Limited Liability Company. What should the bank get for documentation? Do we need the Admission to Transact Business and Articles of Organization?
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?
If a customer has a business checking account in which they require two signatures on checks, are we required to get two signatures on stop payments or will one suffice?
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?