We have had quite a few clients that willingly send funds through Zelle to purchase merchandise and never receive it. To us this is not a REG E claim since they authorized the transfer. Is this correct?
Do we give out Regulation DD disclosures on business accounts?
If a fee is deleted on the closing disclosure in section B and the disclosure was sent out for signing, do we re-disclose to the borrower and show that fee as a Lender Credit?
How often should we approve our policies?
How do we reach a P2P vendor for investigative information when we don't
have a real agreement with that vendor? We've been unable to reach them.
Do we interest report on every account?
Is it okay to request gender information on deposit application?
If the board is ultimately responsible for compliance, what is the compliance officer’s role?
So, if my customer initiated the Zelle transfers to bad guy- is the customer
liable? Bad guy calls our customer, states to be from the bank, has the customer login to
their online banking and the customer is the one who is sending funds...who is pushing the
submit button...is this the customer loss?
If an LLC is doing business under a trade name such as "ABC LLC dba John's Farm Supplies," what is needed for beneficial ownership?
I know the ABC LLC is required to have beneficial ownership and control prong information, but what about the dba John's Farm Supplies, does it need anything separate?