Most Popular Compliance Content
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?
Reg E Provisional Credit for Closed Accounts
03/02/2009
Reg E Commentary 205.11(a)-4 requires banks to comply with error resolution procedures for claims on closed accounts. However, Reg E does not provide guidance on how to provide provisional credit in such cases and 205.11(c)(2)(i) indicates crediting customer's account. Our thoughts are to credit another account owned solely by the customer and if no such account exists, to ask the customer for direction on providing provisional credit. If a customer requests a check in the amount of the credit, is a bank required to deliver a check since this provisional credit cannot be reversed as provided by 205.11(d)(2) if the claim is denied?
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?
Appraisal Review Fee
03/02/2009
If our institution charges an appraisal review fee and the review appraiser is an employee of the bank, is that charge considered a prepaid finance charge for Reg Z?