Most Popular Compliance Content
Carte blanche to an Authorized Signer
01/21/2024
What are your thoughts on allowing customers to give an authorized signer access to their online banking and/or approving them to have a debit card? Would it make a difference if there is a form signed by the customer providing authroization and acceptance of liability for the transactions the signer conducts?
How should a check "for" another read?
01/14/2024
Is a check payable "FOR" someone the same as a Representatives Payee? I've seen checks that do not have "Representative Payee for..." just "For..." John Doe FOR Sally Doe Is this sufficient, or what should it read?
Timing Required on Check Exceptions
01/14/2024
I am working with a new core system and we are discussing our exceptions process for items presented that cannot post for various reasons i.e. NSF, closed account, account restriction, etc. This system will not backdate the item to the date of presentment in cases where we choose to pay it. Is there anything that states the item must be "paid" on the date of presentment? Every other core I have ever used in my 28+ years has always backdated the item to the presentment date.
Advertising CD specials on social media
01/14/2024
We are promoting a CD special on social media. The Reg DD advertising disclosures are a drag. Must we include them? Can’t we say something like “call us for details”?
Stopping Preauthorized Payments
01/07/2024
We currently have outside counsel providing what I believe is inaccurate guidance. However, I'm struggling to find resources I can use to refute their regulatory interpretations. Specifically, this applies to a consumer's right to stop payment under 1005.10(c). Can you please advise how these requirements apply to: 1. Preauthorized transfers for loan payments (we are the lender/servicer) drawn on both external (we obtain debit authorization) and internal deposit accounts; and 2. Preauthorized bill payments both issued against the bank's/vendor's account and debited directly from the consumer's account. We hold the consumer's deposit account and offer the bill pay service.