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?
When training bank employees, what is the minimum training allowed? We are getting a new core this year and it is going to monopolize a lot of time training for it. We want to stay within the legal guidelines and maintain a curriculum, but need to streamline it for core training purposes.
Attention Deficit Disorder
by Mary Beth Guard
Recently, I was diagnosed with CRADD:
Can a savings bank, which is now regulated by the OCC, establish a checking account for a 16 year old, in the Minor's name, as a joint account with the dad. The funds are provided by the dad for gas and other misc. expenses. The balance is very small.
Title 12, Part 18 (Disclosure of Financial and Other Information by National Banks) requires national banks to display signage about the availability of the annual financial disclosure statement. I work for a formerly OTS-regulated federal thrift now regulated by the OCC. Isn't my bank now subject to this requirement?
In reviewing the new Dodd-Frank rules regarding Deposit-Related Consumer Credit Products, (more specifically Overdraft Protection Programs) it appears that banks must now have two Opt-In/Out forms for the customer, one for Reg E requirement and one for Checks/ ACH. We have been asking some other banks to see if this is their interpretation and we have been getting a wide range of responses. Can you clarify this for us?
What is the address for the OCC that we should use for the ECOA Section on our Adverse Action? I am unable to find it on the OCC website. We are a Federal Savings Bank, and as of July 21st, we will be under the OCC.
We have been contacted by our community to sell bracelets on our teller line. The first 100 names of bracelets sold (the tellers would track the names) will go into a drawing for $500 cash. They say it will be open to anyone and not just our clients. Why else would the person be at our teller line if they were not our client? Also, they would like to give something special to the tellers for taking on this added work. I have no idea what "something special" is. We are an OCC bank and I have read through 12 USC 25a. I say that this is a raffle/lottery. Even though we would not be drawing the name of the winner, just selling the bracelets, to me this is still a raffle. Isn't it illegal in it self to allow the bracelets to be sold on bank property? This has nothing to do with deposits or our products or having to become a client of the bank. Would you agree?
I was looking at Appendix B of Part 230 of Regulation DD on BOL. The note under the sample form B-10 for overdraft fee disclosures states that "Use of dollar signs for amounts and grid format for table is required for a format to be considered “substantially similar” to Sample Form B-10." I could not find this requirement in the OCC Comptroller's Handbook or on the regulation. What is the source of this information?
I once read something that stated the Equal Housing Lender logo (EHL) should be displayed anywhere a home loan application is received. Should a national bank have the EHL logo displayed on each loan officer/customer service desk where home loan applications are received or is the lobby poster sufficient?