Most Popular Compliance Content
Signature Card Compliance (FDIC)
03/24/2019
We need more information about compliance when it comes to signature cards. We use add and remove forms for account owners, signers, and beneficiaries when the owner wants to make changes after opening their account rather than printing a whole new signature card that all account owners would have to re-sign. Are these compliant with FDIC requirements when it comes to distinguishing what type of insurance coverage they would have?
Reg E Type of Transfer/Type of Account
03/24/2019
Under Regulation E, section 1005.9(b), Banks are required to include the type of transfer and the type of account to or from which the transfer was made. The commentary doesn't specify how you disclose the type of account under this section (however, it does specify how to disclose this for terminal receipts under 9(a)). So, my question is, is it OK that our periodic statements just state "transfer from account XXXX" instead of specifying the account type or should it be stating transfer from checking/savings?
Customer Wants to Apply for Higher Rate for CC
03/24/2019
If a consumer has a rate on a specific credit card and voluntarily chooses to apply for a higher rate card product with the same institution, does the institution have to protect the lower balance at the lower rate or because the consumer asked for the new higher rate product can the entire balance be moved to the higher interest rate? So say a non rewards card and the consumer wants a rewards card and they agree to moving the existing balance over to new rewards product.
Privately Owned ATM in Business-MSB?
03/24/2019
If a business customer has a privately owned ATM in their business, are they considered an MSB?
Bridge LE: Expedite w/ Investment Acct./TRID Loan
03/17/2019
We issued a Loan Estimate for a bridge loan to purchase a home to be secured with the purchased property and the applicant's current residence. Due to timing circumstances with the applicant and the sellers, the applicant now wants to expedite the purchase by using an investment account and use the TRID loan to get reimbursed. Can I use the same application and re-disclose the LE as a refinance or home equity purpose?
