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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.

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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.

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Reg E Question About Credit Card Fraud

10/25/2020

When a cardholder has a fraud alert on their card and they tell the fraud center that the transactions are NOT fraud, the fraud center reopens the card. Now the customer has roughly 10 or more charges from the same company that she just said were not fraud. Now she is claiming that they are all fraud. (including the original charges) What do we do?

Chamber of Commerce Cash & Prize Giveaway

10/25/2020

Our Chamber of Commerce is hosting a cash & prize giveaway to encourage people to shop local during the holidays. As a member of the Chamber of Commerce, the bank has been asked to pass out tickets as entries to win. Each business has a limited number of tickets. Employees of the bank are not allowed to obtain any tickets from the bank, but can from other businesses participating. My question is, can we offer multiple tickets as incentives for our customers to use other services we offer? Examples would be: 1) A customer comes in to make a deposit= 1 ticket. If they sign up for online banking while here we will offer an additional ticket. 2) A non customer comes in to cash a check= 1 ticket. If they open an account with us we will offer additional tickets. 3) A customer asks about a home loan= 1 ticket. If they qualify, they can earn additional tickets. If they decide to finance with us more tickets.

How to Complete a CTR for Local Diocese

10/18/2020

A question came up during a recent audit in regards to how a CTR would be completed for a local Diocese. This particular Diocese has a few different churches using the same EIN. Our system recognizes large currency transactions that we compare to see if a CTR was completed. My question is, would a CTR be filed on that specific church when deposits of cash are over $10k, or on the Diocese?

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