Vendor Guru Q&A - Compliance

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Latest Compliance - Management Topics

Job satisfaction 101

12/03/2017

What should I do if I want to switch jobs? (Or careers!?)

Education and training

11/26/2017

When is the right time to return for graduate school?

Education and Training

11/19/2017

Why a Bank VP got her Master of Accounting degree (and why you should, too)

Why Master of Accounting over an MBA?

11/12/2017

Why should I pursue a Master of Accounting degree instead of an MBA?

Required Number of Counseling Letters (Overdraft)

06/03/2013

I have recently been put in charge of our Overdraft Management program, but I am fairly new with the program rules/regs. We are sending what seems to me to be a lot of counseling letters to our overdrawn customers. Is there a clear-cut answer on how many counseling letters we are required to send customers?

Reg O Financial Reporting Requirements-Directors

05/20/2013

What are the financial reporting requirements for Directors and their related interests under Reg O? Do they need to produce tax returns or appropriate financial statements annually for their personal loans and loans to their related interests?

Rules/Guidelines on Internal Auditor Independence

02/11/2013

The Audit Committee just hired an internal auditor, and the auditor is an FTE on the bank's books. How do banks achieve independence, (besides the audit charter), when the internal auditor is an employee of the bank? Is it unreasonable that the internal auditor would be subject to employee policy (handbook)? Administratively, whom should the internal auditor report to and to what extent? The rules of internal auditor independence, (banks under $500 mill) are black and white, but don't seem practical in reality. The new auditor is a rookie and is very concerned that in some way he will be asked to do something in contrast to what he is reading and researching about the internal auditor. We are struggling to strike the balance.

Mass Mailing CD to Increase Early Withdrawal Penalty

02/11/2013

Is it acceptable to provide a mass mailing to all CD customers prior to renewal to increase the early withdrawal penalty and how can this be accomplished?

ADA Website Compliance Being Enforced?

01/07/2013

Is any part of ADA Website Compliance currently being enforced?

SAFE Act: MLOs Initial Written Communication

12/17/2012

This question is in regards to the SAFE Act and disclosure of the MLO's unique identifier with the initial written communication. If loan is made to an employee of Sr. Management and the MLO is Sr. Management as well, does the requirement still apply? Obviously these employees know each other well, and since the unique identifier is a tool for customers to get info about the MLO would the disclosure of the unique identifier be relevant in this case? Would an examiner cite an Institution for not having disclosed the unique identifier on initial written communication?

Premium Content View All

Editorial: Are You a Positive Compliance Influencer?

By Patti Joyner Blenden

Compliance: Not Just a Support Function

by Richard H. Harvey, Jr., Esq.

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?

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