I have been trying to find what the requirements are for giving bonuses to open a new account. There are advertisements everywhere of cash offerings, freebies, or giveaways. We’re still stuck on the value of offer cannot exceed $10, however we see TV ads offering $300 to open an account. What compliance issues do we need to address if our offerings go beyond $10? As an example, April is Teach your Children to save month. Marketing has come up with a campaign that if you come by and get a piggy bank and bring it back full of coin with your child and use it to open an account, the bank will also deposit $10 into that new account, or it could be an existing account.
We are one of those hold-out banks that issue passbooks for CD's. Beginning May 1st we are ceasing that practice and just printing a signature card similar to checking and savings accounts. The Mass Banker's Handbook states that: "If individuals lose their passbooks or certificates of deposit a Lost Passbook/CD affidavit must be completed and signed by all parties named on the account.....". My specific question is, does the use of the term CD certificate mean the signature card, or does it refer to institutions that issue actual "certificates", much, like stock certificates used to be issued?
During account opening for a new business customer the branches verify that the required annual filings with the state are up to date. As new accounts are opened for existing business customers a CDD questionnaire is completed for each new account, however the branches are pushing back regarding verifying that annual state filings are up to date. I haven't been able to locate any guidance on whether this is a requirement or a recommended best practice. Can you please advise?
Our attorney posed a question to me that he received from a customer. He wants to know under what circumstance do we change our deposit disclosures? I told him when we have a regulatory change or a policy/product/service charge or other change. Also, I said if the change is adverse to the deposit customer we have to notify them in a certain number of days according the change requirement or regulatory requirement. If the change is to the customer's benefit, we may or may not do a mailing and just post it on the website, social media or on the their statement. Our attorney wants to know the general rules for account agreement changes, when to change them and where it appears regarding the adverse change or customer benefit change. Any thoughts?
Should the owner of a sole proprietor business account cash checks made payable to him personally using the business account?