Most Popular Compliance Content
Paying Better Rates for Putting Skills
09/20/2004
Is there any problem having a "contest of skill" that could earn a customer a lower finance rate or a higher interest rate? We want to give any customer who wants three tries to "sink a putt" in a makeshift golf green that we are setting up in our newly renovated lobby. If they make the putt, they get either 10 basis points less on a loan or 10 basis points more on a CD.
Reg O and Overdraft Fees (Not) Charged
09/20/2004
Under our procedures on Regulation O, if a board member has an overdraft on an account which is less than five days and less than $1,000, no overdraft fee is charged. The bank says they do not charge overdraft fees to customers in "similar" circumstances. Is this a Reg. O violation or not?
Changing Banking Hours
09/20/2004
We're planning on closing a branch for Saturday banking. What kind of notification do we have to give? (We are in Texas.)
SAR Reporting and Due Diligence?
09/20/2004
Suppose you are in a target bank as part of the due diligence team looking at a possible merger/acquisition target. In the course of your due diligence review, you discover suspicious activity that rises to the level of SAR filing. Do you file a SAR? The bank officials obviously can't tell you whether they filed a SAR without violating the law themselves. Do you just discuss it with them and strongly encourage them to file a SAR if they haven't already done so?
Does this soccer promotion get a red card?
09/20/2004
We are planning a grand opening "fun day" which will involve some sports competitions that will likely appeal to kids. Would there be any compliance "red flags" if we advertised that we would make the first deposit of $25.00 towards a savings account for anyone who makes a goal in our soccer competition?