Vendor Guru Q&A - Compliance

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Latest Compliance Topics

Reg D Apply to Savings Used as Security for Loan?

08/18/2019

Does Reg D apply to a savings account that has been used as security for a loan?

Credit Reduction for Extension of IR Lock

08/18/2019

Regarding a lender credit reduction for an extension of an interest rate lock, may a lender reduce a lender credit to extend the lock period? Example; A rate lock expired 4-25-19 and the closing date was 4-28-19. The initial rate lock and Loan Estimate reflect a lender credit of $2000.00 with 4.25% interest rate. The lock was extended through 4-29-19 at the same rate, but the lender credit was reduced to 1800.00. Since the lender credit was reduced based on an interest rate dependent charge, is this acceptable for interest rate extensions? If it is, is there a requirement that documentation confirms the delay was due to the borrower or outside of the lenders control?

FDCPA = UDAAP

08/11/2019

How will the new FDCPA rules impact first-person collections?

Stop Payment Order for Expense Checks

08/11/2019

Is there a minimum or maximum length of time that a stop payment order for Expense Checks is applicable?

Lobby Advertising

08/11/2019

We often have lobby posters advertising products, services, benefits like trips on a discounted price and others things on display so staff can answer questions on these and to promote these items. Do they require the general FDIC advertising statement.

How to Title Acct. for Child w/Deceased Parent

08/11/2019

How do I title an account for a child who is receiving benefits from her deceased dad? Mom is the personal representative.

UCC Check Presentment-Written/Numeric Amounts

08/11/2019

If we have a check presented for payment and the written/numeric amounts on the check differ, are we allowed to write what we took it for above the numeric amount? At a previous institution that I worked for, we wrote it in red ink, so the proof person would know instantly what we read it as.

Dated/Outstanding Expense Check Under $50

08/04/2019

What can we do about a dated and outstanding expense check which is less than $50.00? We cannot locate the payee (an individual).

When do we have to report contest winnings to the IRS?

08/04/2019

We ran a contest and no prize was over $300. We didn’t need to collect non-public private information from the winners since the prizes were small, did we?

Customer Dies w/o an Estate Representative Named

08/04/2019

If an individual account is opened in Tennessee but the customer's address is in West Virginia, and the customer dies without an estate representative named, which state code do we follow as far as the amount the financial institution pays out for funeral expenses, medical expenses, surviving spouse and next of kin?

Premium Content View All

Terminating a HELOC

Question: We are planning on terminating a Home Equity Line of Credit. One of the borrowers died and the remaining borrowers are not making payments on time.

Truncating Social Security Numbers on W-2 Forms

In an effort to help fight the problem of identity theft, the IRS has amended its regulations to permit employers to truncate employees’ social security numbers and taxpayer identification numbers

Cash Deposit Over 10,000 Into Deceased Estate Acct

09/01/2019

We received a cash deposit exceeding $10,000 into a deceased person's estate account (personal checking). The executor is an authorized signor on the account. Will the Benefactor for the transaction be the deceased? Will the executor be listed on the CTR as well? Note- the executor was not the transactor.

Timing Requirement to Return Counterfeit Cashier?

09/01/2019

Is there a timing requirement to return a Cashiers Check that is counterfeit?

Is a discount coupon a bonus?

09/01/2019

If we offer a discount coupon from a local business to a consumer opening a checking account, is that considered a bonus under Truth in Savings?

Security Cameras and Customer Privacy Issues

09/01/2019

Is there any regulation or best practice that says the fact that a person is a customer of a particular bank is private information? My local police department is wanting continual access to my exterior cameras to help them fight crime. I am concerned about privacy issues for customers (among other things).

Guardian Add joint/Authorized Signers-Court Order?

09/01/2019

May the Guardian of an account add joint and/or authorized signers to a guardian account without a court order?

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