Vendor Guru Q&A - Compliance

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Latest Compliance - TISA 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?

Reg DD Disclosures for Negotiated Rate? (APY)

05/20/2018

Are Reg DD disclosures, especially the APY required when, for example, a customer negotiates a bumped up rate for 3 months?

Discontinuing Debit Cash back Rewards Program

03/11/2018

If we discontinue a debit cash back rewards program are we required to provide notice to the customer within a specified time frame, and are we required to notify them at all?

Considerations When Building TIS disclosures

03/11/2018

We are moving our accounts to a relationship style checking with service charge refunds with certain transactional behavior.(ACH, POS, eStatements,etc) What are some considerations we need to remember when building the TIS disclosures?

Compliance Ramifications if Negative IR (TISA)

01/22/2017

I have been instructed to lead a project around compliance ramifications if negative interest rates were to occur in the US. With regard to deposit accounts, would all TISA and other initial disclosures need to be updated to reflect this change. Since the change in terms would negatively affect our customers. This would be quite an undertaking as we have 10 member banks. Would all of our advertisements have to be re-disclosed? Any feedback is greatly appreciated.

Third-party service providers and UDAAP

04/17/2016

We use a third-party service provider to manage some of the benefits of our “Platinum Account”. Are there possible UDAAP issues lurking here?

Notice for Stopping Checks for Money Market Acct.

05/27/2013

If you stop offering the ability to write checks from your money market account, what disclosures or notice must you give to your customers?

NOW Account Rules-7 Day Notice Interest Bearing

04/09/2012

In order to have a NOW account, does the account contract have to disclose the reservation of the right at any time to require not less than 7 days notice in writing before any withdrawal from an interest bearing account?

Excessive Withdrawal Fee Rule (TISA)

09/05/2011

Does an excessive withdrawal fee need to be disclosed on the TISA if it is not an automatic fee? The bank has the option to charge it or not. Would it be considered an incidental fee in this case?

Is TIS Required for an IRA?

06/21/2010

Under 12 CFR 230 (Regulation DD), it discloses Truth in Savings disclosure requirements. I am wondering if an IRA is considered a time deposit account, and if a TIS disclosure is required for an IRA.

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Updating Account Agreements

Question: What is the best way to update customer account agreements for deposit accounts? We have several versions of account agreements currently in use.

You Get What You Ask For

Regulators are generous. Really generous.

Processing Reg E Claims

10/13/2019

We were recently told that the way we process Reg E claims (and have been since before I was here and never had an audit issue besides wording of a letter) is backwards. Here are the few scenarios that will tell me which is right. It's September 2019: 1. If a customer comes in and says they haven’t balanced their statement for 5 years and just realized that $14.99 has been being debited from their account by Amazon since March 2016. Can you tell me what amounts or for what time periods they are owed and for which months/years? 2. If the same scenario happened but the first charge was on April 10th of this year? Can you tell me what they are owed and for which months? 3. Last, if the customer comes in and says that he is balancing his statements for the past two years and found several different charges that are fraud: a. A cable bill that debited for two months after he revoked authorization in 2018. b. Amazon Prime debited monthly for 12 months from June 2018 to May 2019 and he never agreed to it. c. GEICO debited his account $113.00 when he hadn’t authorized it to debit his account for that payment in August 2019.

How to Complete a CTR for an Estate

10/13/2019

How would I complete a CTR for an estate? The Trust Dept. opened deceased customer's safe deposit box and found $75,000 in cash. Funds were then deposited into a trust fund. I know the trust employee will be the transactor but how do we handle the "on behalf of"? Do we just put customer's name even though he is deceased? There's no where to put "The Estate of ..."

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