Skip to content
 

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?

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?

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.

Pages

Premium Content View All

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.

Most Popular Compliance Content

Opening Online Acct. & Funding w/ACH Debits

06/16/2019

Our digital channel team would greatly appreciate your comments and confirmation of our understanding in order to comply with online account opening and funding for new clients with ACH Debits and the ability to hold funds. The questions below relate to an online account opening process for new clients. After completing the online application, approved clients have the option to fund their new account with funds from an external source – an account they hold at another bank - via an ACH Debit and we are the ODFI. 1. Can we place a hold on the initial funds received as an ACH Debit? Our understanding is “yes” because: · an ACH debit does not fall under the definition of an electronic payment under Reg. CC (II.Section229.2 Definitions (p)) Electronic Payment, which imposes no availability requirement, and we are free to hold the funds for a period that we determine. Restricting access to those funds would be reasonable to allow for the debit entry to reach the RDFI and be returned to our bank, the ODFI, if there is a problem. · We are not receiving an ACH credit as we are the ODFI of the ACH debit, and NACHA has no say in when we credit the new account, so there would be no violation of NACHA rules.</ul> 2. Would we be required to provide a hold notice to our online account applicant of the delay in availability or a notice at the time the external funding option is selected that the funds may not be credited to the account for “2-3 days”, or available for “2-3 days” suffice? Our understanding is: · a notice that indicates funds may not be available for x days at the time the customer selects the external funding option and submits their authorization should suffice as it becomes part of our agreement when the customer selects that funding option. · Reg. CC does not impose an availability requirement for ACH Debit transactions, so no Reg. CC hold notice is required. 3. Would our Reg. CC Policy – Funds Availability Notice, need to be updated to refer to availability from ACH Debit transactions? · Model language is silent in this regard, any recommendations or suggestions are welcome.

Pages

Penalties View All

Banker Store View All

From training, policies, forms, and publications, to office products and occasional gifts, it’s available here:

Banker Store

hot right now

image description

Looking for effective, convenient training on a particular subject?

BOL Learning Connect offers more than 200 courses ON-DEMAND or on CD ROM from AML to Reg Z and every topic in between.

Search Topics

Compliance Topics