Our CD (Bankers System copyright) has the language: <i>We may change any term of this agreement. Rules governing changes in interest rates have been provided. For other changes we will give you reasonable notice in writing or by any other method permitted by law. If any notice is necessary, you all agree that the notice will be sufficient if we mail it to the address listed on page one of this form. You must notify us of any change.</i> Does this allow us to change our early withdrawal penalty by a mass mailing to all of our CD customers with a 30-day notice of the change? Also, do we need to be specific by account or can we just provide a chart that shows all of the new penalties?
Must we tell our customer about an exception hold before notifying him by mail?
For Reg D purposes, is there any where I can go to get sample letters/notices sent to customers to notify them of excessive withdrawals on their savings account?
We are starting up a new debit card program. I need help on what policies I need to make sure that I include in our debit card program. Prior we only offered ATM cards. What disclosures do I need to be mailing out? I figured I needed to mail out new EFT disclosure and Reg E disclosure. What kind of offline limits do I need to set for our customers? Is there a Regulation on that?
If a bank does not place holds on deposited items, is a Regulation CC disclosure required since it is not the policy of the bank? This bank sends any questionable check item for collection via mail.
At what point in time is an account considered "opened" for Reg DD purposes? When the consumer sits down at the desk and begins the process? When the Signature card is signed? When the first deposit is made? Currently, we provide the disclosures as part of the opening process, but not at the beginning of the process.
As many banks are becoming increasingly sales minded, many are starting customer calling programs. Is it a violation of a customer's privacy to leave a message on a voice mail or answering machine?
If we have placed a levy against an account, how does it get revoked or removed? Is there specific documents that we must receive in order to do so?
Are we required to disburse a loan on the 4th day of the Rescission period? We have some lenders believing they can disburse the loan any time after the 4th day. As a result, I have run into problems such as when to date the loan on the system and what action taken date to use for HMDA reporting.
We have a customer who has been in Afghanistan for the past 5 years due to their being in the military. The customer has come back to the United States and has discovered unauthorized withdrawals which took place 5 years ago - about a month after they were deployed. Are we in compliance if we deny the claim, or we obligated to pay due to fact our customer was not receiving statements to Afghanistan. The account was charged off in 2007 and customer discovered this on her credit report.