05/28/2023
Is it possible to suppress the final bank statements for ID Theft accounts? Regulation E does not state any exception under it nor are there any regulations against it.
03/12/2023
I am looking for clarification on deposit account statements that must be provided for checking or savings account activity, both consumer and business.
Reg DD does not require a periodic statement for consumer, but Reg E does, monthly if there is Reg E activity and quarterly if not. What about business accounts since neither Reg pertains to those? If not a requirement, is it a best practice?
01/15/2023
Pertaining to Reg DD and combined statements; Under 1030.6, a bank is not required to provide a periodic statement for CDs and IRAs. However, we are providing combined statements for a subset of our clients that that includes information on CDs and IRAs and other account types.
The combined statements do not include APYs (as required by 1030.6) for these account types but includes a "current rate" and includes all the other elements that Reg DD specifies should be on the period statement if one is provided. The official interpretation of 1030.6 states that, "institutions may provide information about an account on the periodic statement for another account without triggering the disclosures required by this section, as long as ..." Our Vendor says that it cannot change "Current Rate" to APY on these combined statements, nor can it remove "Current Rate." Is this a technical violation of Reg DD? If so, what is the potential risk associated with this violation? I have not been able to find any enforcement actions on this issue to help us understand the risk.
09/25/2022
Is there no requirement to send periodic statements for unsecured loans? Does Reg Z require statements only for mortgages and credit cards?
04/24/2022
What is the regulation and where do I find this, on holding bank statements for customers, or is it a bank policy issue?
02/20/2022
Our current periodic deposit account statements show all the required parts for compliance required at 1030.6(a). We show the APY Earned based on the General Formula from Appendix A-2.2.A. If we decide to remove only the “Interest Rate” reflected on all periodic deposit account statements going forward, could we be out of compliance with 1030.6(a)? Also, if we continue to leave the interest rate on the periodic statements, would it be an UDAAP issue, potentially causing confusion for consumers to see a different interest rate on periodic statements than what is on their TISA, due to fluctuations on deposits and debits?
01/23/2022
What is the requirement on sending monthly bank statements to commercial customers? Isn't there something in Reg E that requires customers to receive statements monthly because if there are electronic transactions that are fraudulent, they only have so much time to dispute them? So many of our transactions are electronic these days but we have a customer who wants to see their activity only quarterly. I feel that is too long to wait. I'm looking for proof that this is a banking requirement to send customers statements.
05/16/2021
Is there a general rule, or specifically for the state of illinois, how long do we need to hold statements and account notices that were returned to do an invalid address for the customer?
05/16/2021
Is there a general rule, or specifically for the state of illinois, how long do we need to hold statements and account notices that were returned to do an invalid address for the customer?
11/17/2019
If our Bank is adopting an account closing survey and they want to send it to closed account customers by text and email, does this fall under the
CAN-SPAM rules? They are only requesting feedback, there is no promotional material.