Most Popular Compliance Content
Reg CC Disclosures, Cash Transactions, And Hold Status
06/09/2003
In our Reg CC disclosure we state our hold status for DDA's depending on the Fed districts. However, this hold is only in force for cash transactions so any presented check would trump the hold. If it is not stated in the disclosure that we pay checks on uncollected balances are we in error?
Collateral Grantor & Right Of Rescission
06/09/2003
Collateral Grantor & Right Of Rescission
by Mary Beth Guard, BOL Guru
CIP Customer Notice Sign Size Requirement
06/09/2003
Is there a specific size requirement for the USA PATRIOT Act CIP customer notice sign?
Charging Bad Address Accounts A "Service Fee"
06/09/2003
We have accumulated many accounts that are "no address" accounts. These have accumulated due to the customer not keeping us notified of a new or forwarding address. At one time, most of the accounts were service charged over a period of time and closed on their own due to a zero balance. Since that time, we have merged our regular checking product into a product that doesn't have a monthly service fee, therefore, most of the accounts are no longer service charged and would stay at their current balance (63% of them have less than $50 on deposit) until the funds would be escheated. NOW... the question....we are exploring the opportunity of implementing a service fee for "no current address" accounts. Our initial discussion with compliance was that we could implement that fee to all future "no address accounts" but not to the existing ones since we couldn't truly "Notify" them of the adverse change. I want to wholeheartedly disagree with that since we did disclose at the time the customer opened the account that it was their responsibility to notify us of any address changes.
Insider Lending Limits & Mortgages
06/09/2003
by Mary Beth Guard, BOL Guru