Vendor Guru Q&A - Compliance

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?

Church/Credit Union: Non-government Organizations?

08/01/2021

We are going back and forth as to whether or not a credit union or a church are actually considered non-government organizations? Although we know that they are non-profit, I have read conflicting information and am trying to settle this internally.

Record Retention for Debit Card Dispute Docs

08/01/2021

How long do we need to keep debit card dispute docs? (What is the time of retention?)

Advertising-more than ECOA, TILA, TISA and Fair Housing

08/01/2021

Is following the standard Regs, B, Z, DD and fair housing going to ensure advertising compliance?

Handling Reg E claims on older transactions.

07/25/2021

If an EFT claim is made long after the statement is sent showing the transaction, the rules of investigation don't apply. So why do we investigate any of these claims?

Compliance Info on Paper Checks

07/25/2021

I was wondering if you could point me in the right direction as to where to find more information on compliance for paper checks? Whenever I place a stop payment on a paper check, there's a disclosure that says "this request will expire in 6 months in order to comply with regulatory requirements." For the customers who ask for a more in-depth answer, what can I tell them?

Latest Compliance - Promotional Incentives Topics

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