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?

Debit Card Dispute Documentation

09/23/2018

Can we require a copy of a customer’s receipt if they are disputing the amount of a charge?

Business debit card disputes

09/23/2018

Since Reg E does not apply to businesses, do we have to investigate a fraudulent business debit card transaction?

Removing Safe Deposit Renter In Joint Lease

09/23/2018

When one safe deposit box renter wants to remove the other renter in a joint lease do I: 1 - simply retype a new contract with the remaining renter and keep the same box for the one keeping the box? (basically an update) 2- close out the box and open a new one with a new contract? 3- if I am going to close out the box and open a new one what keeps me from opening the same box prior issued? I currently close out the box and reissue a completely different one with a completely new contract.

Personal Info On New Account Application

09/23/2018

What personal information, such as why a person is disabled, can be put on a new account application? Can you put that the customer is "bi-polar" for the reason they are disabled?

Money Market Eligibility Requirements-Charitable

09/23/2018

What types of accounts are offered to charitable organizations? Can they open a money market account and what are the money market eligibility requirements?

Latest Compliance - Promotional Incentives Topics

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