Most Popular Compliance Content
SCorporation NOW Account Eligibility
11/03/2003
Can an SCorporation, for example a doctor, have a NOW account?
When Must APR Be Disclosed
11/03/2003
I am an assistant manager at an instore branch. The bank compliance officer tells me I can't advertise our mortgage or auto rates without disclosing the APR. It was my understanding that this must be disclosed when actually PROCESSING a specific loan. I thought I had seen newspaper ads w/o the disclosed APR. He told me they were probably mortgage companies. Is he correct? Must we disclose the APR even in advertisements? If so, are there restrictions on HOW it is disclosed, such as spreading the fees over the life of the loan vs. using the first year only (which makes the APR higher)? Are there any fees that we can leave out of the APR?
Fine Points of Determining "Local" Check
11/03/2003
Reg CC Is a normal hold determined by the paying bank's routing number or by the paying bank's address printed on the face of the check? For example, the depository bank located in the San Antonio Fed District accepts a check from the paying bank with a Dallas Fed District routing, the hold is placed for 5 days. Is that correct or would the hold be placed for only 2 days if the bank address is San Antonio?
"Customization" of HELOCs
11/03/2003
My bank has finally rolled out a HELOC product and an openend personal credit line product. Now, I have officers that are pleased to have the product, as long as they can modify it to fit their needs (ie. CP vs program CP+1%; waive the $75 application fee; change term from five years to two years). It is my understanding that these consumer products have to be offered to all with the same terms and conditions, but I need regulatory ammunition immediately to put a stop to the "customization" that is taking place. Help!
Christmas Club Accounts and Reg E
11/03/2003
If a customer has a portion of his/her paycheck to be direct deposited into a Christmas Club (at least monthly) is the Bank required to provide a monthly statement to the customer (Reg E)?