11/04/2002
If our bank offers a box of checks when opening an account, does this trigger the bonus? If so, and our cost is $14.00, how would we report the 4.00 on Reg DD, and would it need to be reported anywhere else?
10/14/2002
When a MMDA account is closed for writing more than three checks within a statement cycle, (Regulation D's requirement), can our institution reopen another MMDA for this customer? If so, what time frame do we have to wait?
09/01/2002
08/05/2002
New customers are given a disclosure before a new account is opened, which includes the model form C3 section "special rules for new accounts." Are we required to provide the customer with a separate funds availability disclosure?
04/01/2002
At the recent Florida Deposit Account Administration seminar, we were told that we must get written permission from a business before obtaining a consumer report from ChexSystem's etc. The question is, must we get written permission to run the report on the business signers, or on the business itself or both?
03/04/2002
I am reviewing a bank's online website. On a few of the web pages for their on-line banking services (transfers, etc.) and on the pages applying for the services, the bank name is at the top of the page but no Member FDIC symbol is on the page. I thought that since the bank name is on the page the Member FDIC symbol must also be on the page; however, the FFIEC's Guidance on Electronic Financial Services and Consumer Compliance states that the official bank sign is not currently required to be displayed on an institution's on-line system. What is their definition of an online system. The bank's internet application page is maintained by Funds Xpress. Is this an online system?
11/05/2001
Lucy Griffin explained to our Minnesota Bankers compliance group that we must not keep photo copies of picture IDs in loan files because of a possible Reg B violation. However, we also do this when we open new accounts (it could be helpful in cases of identity theft, or just so staff will recognize new customers). We also do it when we make a credit card cash advance for noncustomers, as we have experience identity theft there. Can we do this in nonloan situations and not run afoul of Reg B or other regs?
08/27/2001
11/01/1999
06/01/1999