06/09/2019
This question pertains to a Revocable Trust Account. Our client is reluctant to submit the entire Trust document and the attorneys version of what we
need to know does not include list of beneficiaries. Can we insure this account for more than $250,000 without knowing the exact number of
beneficiaries? What if they do submit a list, but make changes to the Trust afterwards without notifying us and the number of beneficiaries changes, are
we obligated to provide the insurance for all?
06/02/2019
The bank has used "replacement" to replace a private label card with a VISA open loop card. Some of the cardholders have not activated their cards, some probably because they threw away the envelope without opening their mail. The bank is considering placing a block on the cards, pending activation from the customer so that the customer can still activate rather
than reapply. The other option is to send a letter to activate the account within a stated time, otherwise the account will be closed. The consumer would need to apply again for a card. IMO, the second choice is a better customer experience in the absence of some foundational regulation to assert one position or the other.
06/02/2019
I was told the 2018 Farm Bill legalized CBD. Is that true?
06/02/2019
1026.53 - Payment Allocation reads pretty clear - payments in excess of minimum payment must be made to the balance with the highest APR and then descending until the payment is exhausted.
But "balance" is not clearly defined. One could argue there could be two different balances. Cycle to date balances (in current cycle) or cycled balances (prior cycle)
For example; suppose a card holders billing cycle is the 1st – 31st with a payment due date of the 21st. The account has the following balances that rolled over from prior cycles;
$10,000 BT Promo at 0%
$225 Purchase at 11.99%
On the 21st the card holder makes their minimum payment of $25 which is applied to interest, fees and balances on the account in accordance with Regulation Z.
On 23rd the card holder makes a $500 purchase at 11.99% and a $2000 cash advance at 12.99%.
On the 28th the card holder makes an additional payment to the account of $3000. Should the additional (excess) $3000 payment be in the following order;
$2000 to the cash advance balance at 12.99%.
$700 the purchase balance at 11.99%
$300 to the BT Promo at 0%
or
Do not apply any of the excess payment to the transactions that occurred in the same cycle.
Alternatively, the payment is applied to the balance in the prior cycle:
$200 to the purchase balance at 11.99%
$2800 to the BT Promo balance at 0%
and nothing to the cash advance balance
What is correct?
06/02/2019
We received a letter from another bank with a check for collection. It was returned to them as NSF and they would like us to collect on it. We are wondering if it is 10 business or calendar days that we as the bank needs to look?
06/02/2019
We have a consumer customer that received a fraud alert on his debit card for "Google Roblox" and he confirmed not his. It was hot carded and a new card was given to him. A week later another fraud alert was placed for "Google Supercell". He said ok to that transaction so card was released from warm status. A month later another fraud alert was placed for "Google Roblox" and he said fraud. After, a month he is claiming fraud on over 75 transaction on both Google Roblox and Supercell.
Does he have charge back rights for both or just Roblox?
05/27/2019
I am seeking your advice regarding an account we are preparing to open for a legal entity which is represented by an individual given power of attorney.
The potential customer is a business registered with the Secretary of State, making them a legal entity who has given power of authority to a person that is not affiliated to the business. This person has come to open a business account in the company's name. The directors are from India and according to their Articles of Incorporation show the business located locally. Our question is, can an individual who is given power of attorney on behalf of a legal entity open an account for the business?
05/26/2019
We have an opportunity to place one of our ATMs at a Mall location in Nebraska. Currently we do not have any branch locations in Nebraska. I was trying to find any information on whether or not that is acceptable. I don’t know if by regulatory prohibitions we are unable to place an ATM in Nebraska without a branch in Nebraska? I don’t know if limited service branch makes any differences either but I thought I would ask if it is a possibility.
If you have any guidance on where I could find information about this topic I would appreciate it.
05/26/2019
If a client makes a claim that the ATM did not deposit either cash or a check in the correct amount, however does not recall the amount of the cash or check, what should our bank do if the investigation goes beyond 10 business days when provisional credit would be owed?
05/26/2019
Would HR 1595 provide protection when lending to MRBs?
