As a mortgage lender am I able to offer to waive loan administration fees for certain customers, if the pricing is to favorable for the Bank?
Does Reg B/Reg O/Reg E address an ad hoc overdraft decision process? If we choose to waive OD/NSF fees for a customer with what we believe is a profitable relationship and charge those customers who are less profitable, could this be seen as an unfair practice? Should we have an established guideline on when to waive and charge?
Is it a Reg O violation to waive an automatic savings/deposit account transfer fee to cover an overdraft for an insider?
When we receive notice of non-payment of a deposited item from the paying bank, Reg CC section 229.33 requires that we notify the customer when it is a large item. Can we hold the funds in the account until the item is returned and do we have to provide a Reg CC hold notice? Does this also apply for any amount, not just large items?
What is the minimum number of days you must charge on a CD penalty?
Is it a violation of Reg O to waive the service charge for excess withdrawals on a money market account owned by an executive officer? The excess withdrawals were inadvertent, not a practice.
We are a national bank. We have a policy that all employees take a consecutive two-week vacation. This imposes a hardship on some departments and employees and we end up with waivers from those not empowered to do so. What can we do?
We would like to start a customer reward program where we pay existing customers $10 for every new customer they refer to us. Are there any regulatory or compliance isssues that this would raise?
We are considering giving ATM surcharge refunds to a specific group of customers. Would we be required to report these refunds to the customer (and IRS) as income on a 1099INT or 1099-MISC?
Is there any problem if we waive wire transfer fees for directors or their related interest? Also, if we pay a higher interest rate on a certificate of a director, is there a problem? The directors are good customers and keep high balances in their deposit accounts. The fee waiver and rate bump are because they are good customers, not because they are directors (all directors are not given the reduced fees and better rate). I hate to penalize a director for being a director.