My accounting department asked whether there were any compliance issues with sending a blanket letter to our vendors (not customers) to request they provide ACH info so we can pay them more efficiently.
I don't see any issues with paying via ACH, but I am concerned we may need to include some privacy disclosures or some such. Any guidance?
A large national retailer is now issuing in-store debit cards, that post transactions to our bank customers account as ACH debits. These are not credit cards - they are debit cards for use only at the designated retailer - swiped and signed just like any other card - only debiting the bank account. Our customer signed up for the card at checkout, provided her banking information, and received a discount for her purchase. One month down the road, she has $900 in debit card purchases that have posted to her account on a card that she says she never received. Can you please describe what would be considered the best practices for a bank in a dispute situation like this? And does the large retailer have a Reg E responsibility here, too? I am particularly thrown here because it is clear that she authorized the ACH debits - but the card purchases were fraudulent. With no control over the instrument or the agreement associated with it, we feel a little blindsided by this new type of dispute.
We are starting up a new debit card program. I need help on what policies I need to make sure that I include in our debit card program. Prior we only offered ATM cards. What disclosures do I need to be mailing out? I figured I needed to mail out new EFT disclosure and Reg E disclosure. What kind of offline limits do I need to set for our customers? Is there a Regulation on that?
Should the attorney fees appear on the third page of the HUD 1-A (which is the comparison sheet with the original Good Faith issued)? It is to our knowledge that they should only appear here if the borrower selects their own attorney to prepare their title work (not an option at our bank). Therefore, we do not include this comparison. Just wanting to make sure that we understand this correctly.
What happens if the final GFE is in excess of the 10% threshold due to the borrower choosing to elect their own title company rather then the one provided by the Bank initially? What should the bank do if they are ready to close on the loan?
When a customer writes a check to a third party and the third party electronically converts the check and it comes through as an ACH ARC transaction, shouldn't the bank treat these as checks and not ACH, if the system can distinguish these? Also, if the customer uses online bill payment and requests that a check be issued to a third party, should these be counted under the "6" or "3" rule? The request was made online, but a check is issued.
When a real estate purchase loan goes to a closing company they prepare and send the HUD for the bank to approve. When they disclose fees such as appraisal, credit report and flood they show the funds being paid to our bank instead of the actual service provider. Are we headed down a bad road?
I work for a third-party service provider for financial institutions in the compliance area for credit cards. I am trying to get my hands around a procedure due to non-compliance and there is no definition of POS that I can find. The problem is that I am fighting with the manager regarding the error resolution 45-day requirement vs the 90-day requirement. She is telling me that everything we do is POS and I need to verify that. My thoughts about a POS were that it was always a pin-based transaction and if you use your debit card as a credit card through Visa or Mastercard it falls into the Reg Z realm. Can you help me with this?
How can a bank achieve assured compliance given the constrained information security budgets today?
What are the highest risk customers for money laundering and what are the specific red flags for unusual transactions within that customer group?