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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?

Minimum Training Allowed for Bank Employees

03/04/2013

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.

OCC Checking Acct. in Minor Name as Joint w/Adult?

06/25/2012

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.

Disclosure of Financial & Other Info by National Banks

04/30/2012

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?

New Dodd-Frank Rules on Two Opt-In/Out Forms

01/02/2012

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?

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Reg Z required statements

09/25/2022

Is there no requirement to send periodic statements for unsecured loans? Does Reg Z require statements only for mortgages and credit cards?

Notice when Cutting Off mRDC

09/25/2022

Is it a requirement to send a notice to a mobile remote deposit capture (mRDC) customer who apprars to be abusing the program? We suspect a customer of "kiting" between financial institutions. Were we to shut off access to mRDC, do we need to notify them in writing, or with any specific content in the notice?

Garnishment of CD Pledged to Loan

09/25/2022

We have a certificate of deposit pledged to a loan. The CD amount exceeds the loan balance by a couple thousand dollars but the original hold was even greater as the loan originated at 60% of its original amount. We recieved a garnishment which will include this CD. Are we obligated to decrease the hold amount to the balance of the loan on the date of receipt of the garnishment and send the excess funds to the court or does the full amount of our original hold superceed this, meaning we would report there are no funds available? I am in Oklahoma if it is a state law issue.

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