Vendor Guru Q&A - Compliance

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Latest Compliance - Savings Accounts Topics

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?

Popmoney Considered Automatic Transfer? (Reg D)

07/01/2018

Is Popmoney considered an automatic transfer with regards to Reg D (excessive withdrawals) limitations?

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?

Does Regulation CC Apply to Savings Accounts?

12/18/2016

Does Regulation CC apply to savings accounts?

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?

Multiple Reg D Violations In 12 Month Period

01/05/2015

If a customer has 3 Reg D violations in a 12 month period, can the bank keep the account a savings account, but turn off the interest to make it non interest bearing?

Reg D Warning Letter for Excessive Transactions

05/26/2014

What happens if a bank sends two warning letters for excessive transactions of a savings account, Reg D, but the bank does not follow thru and allows the account to continue excessive transfers. (the account has a balance of $125K)

Excessive Transaction Reports and Eagle Cash Cards

01/13/2014

The Treasury is promoting Eagle Cash cards for servicemembers. Their FAQs include an explanation that the transactions will be debited from the servicemember's checking or SAVINGS account. These are starting to show up on our excessive transaction reports. We are unable to contact most of these customers because they are deployed and they cannot easily resolve this anyway. Anything we do we will be criticized for...close the account for excessive transactions and we deny servicemembers access to their funds. Leave the accounts open and we are in violation of Reg. D. Is anyone else encountering this problem and if so, how are they handling it?

Excessive Transaction Reports and Eagle Cash Cards

01/13/2014

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Marketing Opportunity

In a release supporting "America Saves Week," the FDIC stated that its research shows that 30% of American households do not have savings accounts.

COPPA and Third Party Vendors

FTC has proposed revisions to the Children’s Online Privacy Protection Act (COPPA) rules to enhance the coverage of the rules.

Easier Way to Sign Up for E-Statements: In-person

04/21/2019

We would like to create an easier way for our consumers to sign up for E-Statements. What are the requirements, compliance wise for this? Currently, our customers need to log into their online banking, view a PDF disclosure that generates a "code", and customer then has to type in code and agree to terms and conditions. Compliance wise- can consumers just sign the disclosure/consent in person at lobby?

Master Repurchase Agreement Sample/Copy

04/21/2019

I would like a sample of a Master Repurchase Agreement. Can you help me in finding a copy of such?

Hold on Savings Due to Excessive Overdrafts?

04/21/2019

Can a hold be placed on a savings account due to the customers excessive overdrafts on their checking account? Would this be a Reg CC violation?

How Long to Retain "Referral Authorization"

04/21/2019

Any idea how long we need to retain a "referral authorization" that we have between a collection agency and our customer?

Exempt Non-Listed Business: Savings Acct. CTR

04/21/2019

Are savings account transactions considered exempt from CTR reporting for the business customer that is an exempt non-listed business? What about cash payments to a loan account? From 31 CFR 1020.315: The exemptible accounts of a non-listed business or payroll customer include transaction accounts and money market deposit accounts. From Federal Reserve Act 19(b)(1)(C): The term "transaction account" means a deposit or account on which the depositor or account holder is permitted to make withdrawals by negotiable or transferable instrument, payment orders of withdrawals, telephone transfers, or other similar items for the purpose of making payments or transfers to third persons or others. Such term includes demand deposits, negotiable order of withdrawal accounts, savings deposits subject to automatic transfers and share draft accounts.

Latest Compliance - Savings Accounts Topics

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