Vendor Guru Q&A - Compliance

Latest Compliance - Savings Accounts Topics

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?

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?

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?

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?

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COPPA and Third Party Vendors

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Threshold for Regulation Z Coverage (Non-RE Loans)

02/16/2020

Should non-RE loans that exceed the dollar threshold for Regulation Z coverage still be considered consumer loans as far as coding and reporting? We have a difference of opinion. One side believes the Reg Z exemption essentially changes the loan into a commercial loan in every way. The other thinks that the disclosures in the documentation is where the exemption is primarily seen and the loan should be coded and reported exactly like any other loan of its type that is under the threshold. Any clarification would be appreciated.

Latest Compliance - Savings Accounts Topics

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