Most Popular Compliance Content
Address Discrepancy Credit Report
03/09/2009
We are having a difference of opinion on this topic at our institution. When you are taking an application from a new consumer and receive an address discrepancy alert on a credit report, are you required to address that alert if you decide not to extend credit and a denial is sent?
Reg CC Hold Confusion
03/09/2009
We have a 2:00 PM cut off time. Based on the Reg CC guidelines we should begin counting hold periods the first business day after the deposit date. If I accept a check for deposit that requires a two business day hold on Monday at 3:00 PM, do I begin counting on Tuesday or Wednesday?
NSF Fee Change Notice
03/09/2009
We are getting ready to change our non-sufficient funds (NSF) fee. What obligation do we have to notify our customers besides them getting the NSF notice after the check has been returned or paid?
New TILA Pre-Disclosure?
03/09/2009
I have heard that a new truth in lending pre-disclosure will be required next year, but I don't see anything about it in the regulation. Will this be required and if so, where is it stated?
IRA Exemptions & Reg R Guidelines
03/02/2009
Under the new broker push-out rules Reg R guidelines, it looks like banks do not receive the exemption for IRAs on which they are named as a trustee. Our trust department IRA governing documents name our bank as trustee. It would appear then that we would not meet the requirements of the exemption. Is this the correct interpretation of the IRA and Employee Benefit Accounts exemption language or do we receive the exemption because the accounts are offered/managed in the trust department?