Vendor Guru Q&A - Compliance

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.

CRA Changes for Intermediate Small Banks

02/16/2020

Our bank is an Intermediate Small Bank under the current CRA rule, with an asset size of $750 million. Will we still be treated differently from large banks under the proposed rule?

Platform staff sent emails & CAN-SPAM

02/16/2020

Does CAN-SPAM apply to those emails sent by platform employees to let their preferred customers know of new rates, etc.?

Loan Policy Exception Tracking Best Practices

02/16/2020

Are there best practices for tracking loan policy exceptions?

TILA Disclosures Given to Business Entity (Reg Z)

02/16/2020

If TILA disclosures are provided in a loan to a business entity and the APR is understated - is this a violation of regulation Z although loans to business entities are exempt from the coverage of Regulation Z?

Threshold for Regulation Z Coverage (Non-RE Loans)

02/16/2020

Should non-RE loans that exceed the dollar threshold for Regulation Z coverage still be considered consumer loans as far as coding and reporting? We have a difference of opinion. One side believes the Reg Z exemption essentially changes the loan into a commercial loan in every way. The other thinks that the disclosures in the documentation is where the exemption is primarily seen and the loan should be coded and reported exactly like any other loan of its type that is under the threshold. Any clarification would be appreciated.

Latest Compliance - TISA Topics

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