Most Popular Compliance Content
Time Limit to Recall ACH
10/02/2022
Our credit union received a request for a return for an ACH transaction that was made in error. The request was sent to via fax on 9/1/2022. The original transaction was dated 7/22/2022 and is now outside of the return time frame. Is the CU required to honor this return and, if so, is it acceptable to honor a fax'ed request? We are under the impression that it would need to go through the Federal Reserve. Any advice that you can offer would be greatly appreciated.
Garnishment of CD Pledged to Loan
09/25/2022
We have a certificate of deposit pledged to a loan. The CD amount exceeds the loan balance by a couple thousand dollars but the original hold was even greater as the loan originated at 60% of its original amount. We recieved a garnishment which will include this CD. Are we obligated to decrease the hold amount to the balance of the loan on the date of receipt of the garnishment and send the excess funds to the court or does the full amount of our original hold superceed this, meaning we would report there are no funds available? I am in Oklahoma if it is a state law issue.
Reg Z required statements
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?
Notice when Cutting Off mRDC
09/25/2022
Is it a requirement to send a notice to a mobile remote deposit capture (mRDC) customer who apprars to be abusing the program? We suspect a customer of "kiting" between financial institutions. Were we to shut off access to mRDC, do we need to notify them in writing, or with any specific content in the notice?
Large Bank and Intermediate-Small Bank CRA exams
09/25/2022
What's the difference between a Large Bank CRA exam and an Intermediate-Small Bank CRA exam?