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?

Customer Violates Reg D for a 3rd Time

08/25/2019

When a customer violates Reg D for the third time, we take away whatever was abused; such as internet transfers, ACH etc. Can we give what we took away back to the customer or is it gone for good, or do we not take away something and just close the account? I'm not sure what is a best practice.

Opening Professional Limited Liability Company

08/25/2019

We have a customer wanting to open an Professional Limited Liability Company. What should the bank get for documentation? Do we need the Admission to Transact Business and Articles of Organization?

CD Product with All Interest Paid Up Front

08/25/2019

Our bank is exploring the idea of a new CD product in which all the interest is paid up front on the date of initial deposit. In the case of early withdrawal, are we able to deduct the penalty from the principal since there would be no interest accruing during the CD term?

Business Checking-2 Signatures for Stop Payment?

08/25/2019

If a customer has a business checking account in which they require two signatures on checks, are we required to get two signatures on stop payments or will one suffice?

Reg D Apply to Savings Used as Security for Loan?

08/18/2019

Does Reg D apply to a savings account that has been used as security for a loan?

Latest Compliance - Promotional Incentives Topics

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