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Latest Compliance - Savings Accounts Topics

New Reg D Regulation Changes for COVID-19

05/24/2020

For the new Reg D regulation changes for COVID-19 in which withdrawal limits are waived, does the bank have to provide a notice of change within 30 days of the change or not? Is the notification requirement waived if the change is temporary and/or the change is permanent?

Violation of Reg for a Third Time

01/12/2020

When a customer violates Regulation D a third time in a 12-month period, how do most other banks prevent the customer from just opening another savings account to possibly continue excessive transactions? If a Reg D policy is established to prevent multiple savings account opening over a period of time, how do banks monitor such activity among their various branch locations?

Add Higher Balance Tiers On Investment Savings

07/14/2019

Our private banking area is requesting to add two higher balance tiers on an investment savings account. There is no regulation or rule that would hinder this correct? The only thing I can see is if we are not offering this to other bank customers, but only to these high end customers.

Regs/Requirements for Time Deposit Accounts

02/17/2019

Our company is wanting to offer Time Deposit accounts. I have read Reg. DD and I see that Time Deposits have certain restrictions on withdrawal periods and penalties but I don't think they are much different than Certificate of Deposits and Auto Save IRA CD's. Basically if we adhere to TISA requirements are we okay to offer these or should I be looking into any other regs or requirements?

Savings Account w/ Higher Rate-APY Disclosure

02/04/2018

We want to offer a savings account for students. We are thinking of offering a higher rate on the first $1,000 deposited and then our normal rate on balances over that. This will be effective for one year and then the rate goes to our regular savings rate at that time. If we put up a banner on our building and state the higher rate, do we need to also state an APY on the banner? And what balance would we use to disclose the APY? The APY for $1,500 and $2,500 are considerably different.

Reg D Savings Statement: How Many Transactions

06/04/2017

Our savings statements are generated every quarter. We recently converted our banking core, and our new core is counting Reg D transactions for every 90 days instead of 30/31 days. My question is, per Reg D, should the customers be allowed 6 transactions per 30 days or 90?

Converting Passbook Savings to Statement

04/27/2015

We are converting all of our passbook savings accounts to statement savings. The disclosures originally provided to existing accounts did not differentiate between passbook and statement accounts. Are we required to provide a 30-day change in terms notice to customers whose passbook accounts will be converted?

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COPPA and Third Party Vendors

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Reg E Question About Credit Card Fraud

10/25/2020

When a cardholder has a fraud alert on their card and they tell the fraud center that the transactions are NOT fraud, the fraud center reopens the card. Now the customer has roughly 10 or more charges from the same company that she just said were not fraud. Now she is claiming that they are all fraud. (including the original charges) What do we do?

Chamber of Commerce Cash & Prize Giveaway

10/25/2020

Our Chamber of Commerce is hosting a cash & prize giveaway to encourage people to shop local during the holidays. As a member of the Chamber of Commerce, the bank has been asked to pass out tickets as entries to win. Each business has a limited number of tickets. Employees of the bank are not allowed to obtain any tickets from the bank, but can from other businesses participating. My question is, can we offer multiple tickets as incentives for our customers to use other services we offer? Examples would be: 1) A customer comes in to make a deposit= 1 ticket. If they sign up for online banking while here we will offer an additional ticket. 2) A non customer comes in to cash a check= 1 ticket. If they open an account with us we will offer additional tickets. 3) A customer asks about a home loan= 1 ticket. If they qualify, they can earn additional tickets. If they decide to finance with us more tickets.

How to Complete a CTR for Local Diocese

10/18/2020

A question came up during a recent audit in regards to how a CTR would be completed for a local Diocese. This particular Diocese has a few different churches using the same EIN. Our system recognizes large currency transactions that we compare to see if a CTR was completed. My question is, would a CTR be filed on that specific church when deposits of cash are over $10k, or on the Diocese?

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