03/17/2024
I am commercial loan broker, I have applied my client for an SBA 7a Loan, and we are near closing. The appraisal report is done, but the banker with whom I communicate, said to me that the appraisal is only available after closing. Aren't they allowed to send it, or he is doing it on purpose so we don't go with another lender?
03/17/2024
Can the legal address be used on flood policy instead of the physical address? This issue has come up where the insurance company is refusing to change the address. We asked if we could use the legal address instead.
03/10/2024
We were recently audited and it was noted that because a customer can immediately withdraw funds from a deposit made that same day, that we should be disclosing as a same day availability bank. instead of next day availability. What is your opinion and how do you recommend wording the change on policy, notices, and disclosures? It seems most examples I find are all next day examples.
03/10/2024
What is the difference between renting, leasing, or selling equipment to customers for Merchant Capture (remote deposit devices)?
Are there any rules/regulations related to leasing or renting this?
03/03/2024
We continue to have issues collecting customers current physical addresses when opening new accounts. Our frontline thinks they find loopholes in our policy, deviating from the intent of the policy, and they create larger problems.
Is it permissible to have a policy or procedure in place for changing the address on a new account for a new customer within 30 days of the date opened? Say if a customer opens an account on the 10th and then comes in on 21st to change their address, do other banks have a policy to collect a proof of address at this time since it is a new account?
03/03/2024
Can a check that was returned as FROZEN ACCOUNT be redeposited?
02/25/2024
I have a husband and daughter who have been appointed conservator for his wife (mom). According to the court documents the annual accounting to the court is waived. Can I open the account as joint for the husband and wife showing he and the daughter as conservators?
02/25/2024
We need an advice for below situation.
1. Our customer cashed a check for $9,230 from another bank at one of our branches on 11/21/23.
2. On 11/27/23 we received a return for this item as Stop Payment.
3. On 11/28/23 we processed a late claim returned to Fed and received the credit from Fed same day.
4. On 1/19/24 we received a late returned debit from the Fed to deal directly with the other bank. We contacted the other bank as they insisted that it wasn't a late return.
How can we resolve this situation and how we can ask other bank to pay us?
02/18/2024
We have a business customer who had an employee negotiate their payroll checks a second time. This employee deposited their payroll checks through a mobile channel with their bank over a year ago and then deposited them again.
They cleared our customers account because our duplicate detection only goes back a year. Our customer did not reconcile or review his accounts to notice the duplicate payments and wants to hold the bank responsible. They total about $11k. We already tried returning the checks for duplicate and as expected, they were returned for "Late Return".
I am looking for any input as to how we can recoup the funds? The bank of first deposit (PNC) did take in stale dated checks as well as having their customer not adhere to mobile banking terms. Any input would be appreciated.
02/18/2024
I am new to the compliance function so I apologize if this does not make sense. My question addresses Reg DD and a CD interest payment date vs. maturity date.
Here is an example: a CD term is 6 months and interest is paid every 30 days.
Since there are more/less than 30 days in some months the interest payment date does coincide with the maturity date, so there are generally a few days between these dates. I am unable to find anything in the TISA reg about this. How and when is interest paid in relation to the maturity of the CD?