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.

Easier Way to Sign Up for E-Statements: In-person

04/21/2019

We would like to create an easier way for our consumers to sign up for E-Statements. What are the requirements, compliance wise for this? Currently, our customers need to log into their online banking, view a PDF disclosure that generates a "code", and customer then has to type in code and agree to terms and conditions. Compliance wise- can consumers just sign the disclosure/consent in person at lobby?

Master Repurchase Agreement Sample/Copy

04/21/2019

I would like a sample of a Master Repurchase Agreement. Can you help me in finding a copy of such?

Hold on Savings Due to Excessive Overdrafts?

04/21/2019

Can a hold be placed on a savings account due to the customers excessive overdrafts on their checking account? Would this be a Reg CC violation?

How Long to Retain "Referral Authorization"

04/21/2019

Any idea how long we need to retain a "referral authorization" that we have between a collection agency and our customer?

Exempt Non-Listed Business: Savings Acct. CTR

04/21/2019

Are savings account transactions considered exempt from CTR reporting for the business customer that is an exempt non-listed business? What about cash payments to a loan account? From 31 CFR 1020.315: The exemptible accounts of a non-listed business or payroll customer include transaction accounts and money market deposit accounts. From Federal Reserve Act 19(b)(1)(C): The term "transaction account" means a deposit or account on which the depositor or account holder is permitted to make withdrawals by negotiable or transferable instrument, payment orders of withdrawals, telephone transfers, or other similar items for the purpose of making payments or transfers to third persons or others. Such term includes demand deposits, negotiable order of withdrawal accounts, savings deposits subject to automatic transfers and share draft accounts.

Latest Compliance - TISA Topics

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