Most Popular Compliance Content
Same Online ID for Business & Personal Account?
11/17/2008
I'm not sure if we have crossed any compliance or legal lines by allowing the following with regards to online banking access. A customer is both an officer and an authorized signer on a business account, either a corporation or LLC. This person also has a personal DDA account with the bank. The customer has applied for and been granted access to view his business account via our online banking product. The same customer also wants to view his personal account via online banking, but he does not want to have a separate access ID and password for the personal account. To honor the customer's request we have granted viewing privileges to both the business and personal DDA accounts under one access ID and password. Can you tell me if we have entered a gray area by doing this? Should the bank insist on keeping business and personal accounts separate in online banking by having different access IDs for both types of accounts?
Just Say APY?
11/17/2008
When responding to oral inquiries about interest rates, is it necessary to use the phrase annual percentage yield when stating the APY? Is it acceptable to just say APY?
New FDIC EH Lender Poster
11/17/2008
Our legal department just notified us that the Equal Housing Lender poster will need to be updated because the FDIC is making changes. Can you tell me where I can get copies of the updated poster? Is it available in both hard copy and PDF format?
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.
Automatic Transfer Service Account Eligibility
11/10/2008
Who is eligible to maintain an Automatic Transfer Service (ATS) account? Is the eligibility the same as NOW accounts?