On mortuary trust accounts, can the trustee sign the W-9 form on behalf of the customer and certify that there is no backup withholding, or do customers have to sign for themselves?
We are a community bank, and have a question in regards to Reg P. Do we need to do an annual vendor review for our non-affiliated third parties or do we just need to obtain their financials/annual report?
Everyone is in a rate war. We would like to advertise in our local paper that we will match and maybe even beat the competitors rate, but only if it is an advertised rate and they can bring the clipping to us. However, we only want to accept newspaper ads, not direct mail or other special offers. Is that possible and what compliance rules would apply since we are not quoting a rate?
Our overdraft processing is creating what I think may be a problem when we try to comply with the new interpretation of the statement disclosure requirements in section 230.6 of Reg DD. That interpretation requires that we use different "labels" for our fees for paying overdraft items and our fees for returning items.Our processing system makes certain preliminary overdraft pay/return decisions during the overnight processing cycle, including the imposition of either an overdraft item fee or a return item fee, but almost every day we change some of those parameter-driven decisions. For example, we might decide to pay an item even though the system had suggested it be returned. Do we need to change the "return item fee" that the system had imposed to an "overdraft item fee" when we make a change of this sort?
FCRA states "any person who makes or arranges loans and who uses a consumer credit score... shall provide..." the disclosures then defined. If a credit report containing a credit score is obtained, but as a matter of policy, the credit score plays no part in any credit decision are we required to provide these disclosures?