Vendor Guru Q&A - Compliance

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Latest Compliance - Promotional Incentives Topics

Promotional Incentives & Definition of Lottery

09/17/2017

We want to do a promotion/fund raiser at a festival for our local food bank. We will be promoting our new Popmoney product. The idea is that we will have a wheel to spin with 36 varying amounts on the wheel from $1.25 up to $15. Festival attendees will be allowed an opportunity to donate $1 to the food bank for a chance to spin the wheel. Every spin will win at minimum $1.25 which we will then send to the individual via popmoney. We will set a $750 maximum giveaway limit for the festival, and when we reach that amount, we will shut down the event. All of the $1 donations will be given to the food bank and we will completely fund the amounts given to the participants, including the fee for each popmoney transaction. Based off what I have read on the Federal Deposit Insurance Act Sec 20, lottery is defined by "the advance of money or credit in exchange for the possibility or expectation that one or more BUT NOT ALL of the participants will receive by reason of their advances more than the amounts they have advanced". Since all participants would receive more than they advance this would not be a lottery correct? If I am correct are there any other issues I have not considered?

Offering Promotional Incentives

06/17/2002

We are looking to promote our basic no interest checking product. We originally wanted to offer new customers $25.00 to open an account but could not do that directly due to the constraints of Reg. Q. The idea has now been proposed to offer the new customer $10.00 (ok under q.) to open the account and an additional $15.00 if he opens a Visa Debit Card as well. Would the additional money still be governed under Reg. Q? What other issues are raised?

Licensing Privately Owned ATMs & ATM Operators

06/09/2019

FFIEC Guidance on Privately Owned ATMs is ambiguous regarding registration and licensing requirements of Privately Owned ATMs and ATM Operators. Where can we locate specific guidance regarding licensing requirements by State/Parish/County for Privately Owned ATM Operators? We know what licenses are required by an entity to conduct business in general, however have not able to locate specific requirements for States other than those in the North East for registering and licensing Privately Owned ATMs and ATM Operators.

Decline Dispute if No Evidence of Invalid Error?

06/09/2019

Our customer says "I canceled my account with the merchant" but does not provide any documents showing the account was canceled or says "my bill was suppose to be $23.00 but I was charged $37.00 and does not provide a receipt. Can the bank, since there is no evidence the error was invalid, decline the dispute?

ID for Cashing Checks & Making Deposits

06/09/2019

What is the proper identification for cashing checks or making deposits?

Revocable Trust Account-Beneficiaries Changes

06/09/2019

This question pertains to a Revocable Trust Account. Our client is reluctant to submit the entire Trust document and the attorneys version of what we need to know does not include list of beneficiaries. Can we insure this account for more than $250,000 without knowing the exact number of beneficiaries? What if they do submit a list, but make changes to the Trust afterwards without notifying us and the number of beneficiaries changes, are we obligated to provide the insurance for all?

Fraud alert and error claim on debit card

06/02/2019

We have a consumer customer that received a fraud alert on his debit card for "Google Roblox" and he confirmed not his. It was hot carded and a new card was given to him. A week later another fraud alert was placed for "Google Supercell". He said ok to that transaction so card was released from warm status. A month later another fraud alert was placed for "Google Roblox" and he said fraud. After, a month he is claiming fraud on over 75 transaction on both Google Roblox and Supercell. Does he have charge back rights for both or just Roblox?

Latest Compliance - Promotional Incentives Topics

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