Most Popular Compliance Content
Debit Card Mailing - Age 70 & Over Excluded
01/26/2009
The bank is thinking about conducting a mass mailing of debit cards to all customers who do not currently have a card. I understand that this may be done so long as we follow Section 205.5 of Reg E. The question is, can we exclude customers age 70 and over from the mailing? All of our accounts have overdraft coverage. I am concerned that due to that fact, the regulators might construe the coverage to be incidental credit, which could potentially mean an age discrimination issue per ECOA. I know that the bank can offer a product that benefits persons over age 62. Do you think excluding those over 70 (or 62) would be a benefit or a detriment? Do you think we can exclude the customers over age 70? Do you think we could use Regulation B's definition of "open-end credit" to get around the "incidental credit" issue?
RESPA - Non-Borrowing Owner Sign Initial TIL & GFE
01/19/2009
Do we need to have a non-borrower owner of title sign an initial TIL and GFE for a RESPA transaction? Reg Z talks about material disclosures, but I can’t find what is considered a material disclosure. Which other documents besides the deed of trust and riders need to be signed by a non-borrower owner of a property?
ATM/Debit Card Applications Retention
01/19/2009
I cannot find the record retention requirement for ATM/Debit card applications in my state's (Connecticut) retention schedule or Reg E. How long do I have to keep ATM/Debit card applications?
Stop Email & Paper Statements Per Customer Request
01/19/2009
We have e-banking customers who do not want to get a paper or email statement because they view their account history online. Are we out of compliance if we stop sending email or printed statements?
CRA Branch Lobby Notice
01/19/2009
We are a branch of a bank whose main office if about 190 miles away. What address do we need to provide on our CRA lobby notice?