If our Bank is adopting an account closing survey and they want to send it to closed account customers by text and email, does this fall under the
CAN-SPAM rules? They are only requesting feedback, there is no promotional material.
During account setup, we would like for the CSR to setup the mobile app information on the core system. The customer will be able to use the app
without having to go into mobile banking and completing a few steps. Should the customer sign any type of disclosure allowing us to do this? Is there
anywhere I can find this information in a regulation?
Is there any regulation or best practice that says the fact that a person is a customer of a particular bank is private information? My local police
department is wanting continual access to my exterior cameras to help them fight crime. I am concerned about privacy issues for customers (among other things).
Can the bank use information from approved closed-end mortgage loan applications (ie property LTV) to offer a pre-qualified HELOC product? Could the bank have the borrower sign an authorization at application of the closed-end loan that indicates the bank may use the information obtained to
offer them other credit products that they might be interested in?
Is it permissible for the government to simply give us the certificate of compliance at the same time they give us the subpoena?
the time the client established a relationship with the Bank?
The FRB last week allowed FRB banks to no longer send an annual privacy Notice if nothing has changed. This is reportedly an interagency exam revision but it is not in the OCC or FDIC data and it only addresses Reg P which the FDIC does not follow. Questions - Are FDIC and OCC banks now exempt from sending an annual Privacy Notice if they are not subject to have to send the notice referenced in the FRB Memo. I cannot find anywhere that the FDIC and OCC have adopted the procedures.
I am currently working on an audit for the RFPA. We have several verification of deposit that come into our bank from state and local government agencies. For example, the local housing authority sends requests pertaining to the Federal Assisted Housing Program. Should we treat these requests as if they came from a federal agency and should they contain the RFPA disclosure?
What have FinCEN’s geographically targeted orders required banks to do?
Should we be waiting for the Bureau to amend its privacy rule before we stop sending annual privacy notices?