Most Popular Compliance Content
Reg D - Excessive Withdrawals
11/17/2008
I'm currently doing a Reg D and Q audit. What are the requirements for savings accounts that have excessive withdrawals every month? Are we supposed to close the savings account and convert it to a DDA or is it enough to send the letters and let them continue to make excessive withdrawals? My compliance officer says there is nothing we can do.
Using 'Secret Questions' for Identification
11/17/2008
With consumers publishing more and more information about themselves online, is using secret questions still a safe way to identify someone?
Key Risk Indicator Identification
11/17/2008
How should a bank identity its key risk indicators?
About Information Gathering Methods
11/14/2008
Can you explain the various information gathering methodsused to assess risk? For example, we are currently utilizing a risk-basedquestionnaire divided into three sections: (1) Industry-based risk - in this casefor a trust company; (2) Systemic risk - risk faced by all corporate entities suchas attrition, and human resource issues; and, (3) Organizational risk - risk uniqueto the company's business plan. With the aforementioned questionnaire, wehave key stakeholders throughout the company completing the checklistassessing key risk areas by assigning a value based on probability of occurrence(low to high, e.g. 1-5), the impact should the risk occur, and a set of five key riskareas, compliance risk, reputation risk, strategic risk, etc.
Tiered Rate Checking Account APY Disclosures
11/10/2008
We are introducing a tiered rate checking account and I am clear on what needs to be included in disclosures, but do I have to disclose different APYs on the statements or can I use a blended APY?