I am trying to understand the Reg D guidelines. Is the use of the 24 hour telephone teller for transfers to transaction accounts and check withdrawals mailed to the member counted within the six allowed? How do I count transfers from a non-transaction to a transaction account made automatically to cover overdrafts?
We are not a HMDA reporting bank, however, I was just told that we still have to collect monitoring information on purchases and refinances of purchases. Is this true, if so where can I find this in the Reg?
We don't offer/promote ODP on commercial accounts, however we do occasionally pay on NSF. My question is if we have an overdraft and we charged them overdraft fees and they did not resolve the overdraft for a month can we charge interest on that overdraft?
I know there is a violation for not reporting loans that should be for HMDA purposes. It was brought up at one of our meetings that it is better to over-report loans for HMDA purposes rather than to under-report. Is that true, or will we be in violation for over-reporting as well? Any clarification would be greatly appreciated.
On a "Sub-S" corporation, what type of documentation is required to identify the company, a certificate or articles of incorporation? Also, are the principals general partners, managers, or officers?