08/02/2010
We will be offering a $25 gas card for new account openings. Under Reg DD, this would be considered a bonus or premium? Would we be required to send the customer a tax form? If so, which tax form and what box do we complete?
03/22/2010
With the recent consolidation of the Federal Reserve Bank districts, basically eliminating the non-local check, how does this impact Reg CC with regard to the availability of deposits made at non-proprietary ATM machines? Can we still hold these deposits for five business days or do we have to reduce this to two days as well? Also, how does this impact the numbers of days we can hold deposits that fall under the exceptions?
03/22/2010
With regard to the changes in Reg CC, are there any revisions to the Special Rules for New Accounts?
08/31/2009
A customer dies and the executor of estate changes certificate of deposit to a CD titled: The Estate of Deceased Customer, then wants to cash in the CD before maturity. Can we charge an early withdrawal penalty? I know if the CD had still been in deceased's name and social we would not charge a penalty.
05/04/2009
We have employees who have joined Facebook, Twitter, Linkedin and the like. These are social networking sites and what employees do on their own time is their own business. Are we responsible for advertising compliance if they solicit business in these sites, as they strive to make new accounts goals?
09/15/2008
Are there any requirements to display a disclosure on the new accounts desk notifying customers that a credit report will be pulled when openings new accounts?
05/05/2008
Our bank would like to pay $100 to every customer who opens a checking account and signs up for direct deposit. The incentive would be paid to the account upon confirmation of the service, which could be 30-60 days from account opening. In looking at the requirements of 217.101(b), I'm concerned that an examiner could argue that duration and minimum to open an account is a factor in the promotion. It goes without saying that an account would have to be established to hold the funds and I understand that direct deposit is an ancillary service. At the same time, the whole objective of the promotion is to get new customers and new accounts. Is this promotion risky from a compliance standpoint? Should we consider this non-employee compensation for IRS reporting purposes?
05/05/2008
When we open new accounts, we like having customers sign up for online banking at that time. Marketing created a form where the customer waives the requirements for demonstrable consent and certifies they meet the hardware and software requirements we have to get our e-statements. Is this satisfactory?
06/11/2007
We would like to give away tickets to a sporting event to customers who open new accounts, but our compliance officer says that the value of a gift to a customer cannot exceed $10.00.
03/26/2007
When closing a consumer account due to stolen checks or a similar reason and opening another account of the same type (same fees, same name, etc.), is it necessary to provide all the disclosures that are normally provided at account opening? This question has come up because we are in the process of changing our account offerings; the new accounts will have different names, fees, etc. The new account TISA disclosures will reflect the new account offerings. When we do a "close and reopen" we can open the same account type as the customer's original account, however, the new account TISA disclosures will not include information on that account type. What is required in this situation?