Most Popular Compliance Content
Adverse Action List for the Examiner
12/01/2008
In preparation for an upcoming exam we have been asked to provide a list of customers or potential customers for whom the bank took adverse action on the basis of its CIP. The adverse action is causing confusion. Under what requirements do we consider it adverse action and put the customer or potential customer on this list?
Business Accounts- Charging Daily Interest
12/01/2008
Our lending department wants to charge business customers daily interest on accounts that remain overdrawn or uncollected for a number of days after the initial infraction. What customer notification is required and are there any regulatory issues about which we need to be aware?
Notice of E-statement Ready for Viewing
12/01/2008
Under the E-Sign Act, is the bank responsible for tracking or assuring that the customer is receiving the notice that their E-statement is ready to be viewed? We have a system where we send the notice to the email address the customer has provided, if it's not a valid address, it gets kicked back to our server, then we send them a paper copy. At a compliance conference, it was mentioned that we need to ensure that the notice we are sending is viewable to the customer, it's not enough that it reaches them, but the customer should also be able to read the notice (i.e. some email servers may not allow customers to read emails in HTML format). Is this this correct? If so, how do we ensure customers are able to receive AND be able to read their notice?
Going Away Celebration - Invite Retiree's Clients
12/01/2008
One of our bank officers is retiring. The branch would like to send out a postcard to her client list inviting them into the bank on her celebration day to say goodbye and have cake. Do we have any privacy issues in doing this since it will be a postcard?
FACTA Verification - Fraud Alert on Credit Bureau
12/01/2008
When granting open-end credit card accounts is it necessary for the bank to call the applicant (if the phone number is provided in the bureau statement) in the event that they have an extended fraud alert on their bureau or can the bank leave a message and accept a return call from the applicant and verify the applicant's bureau contact phone number from the bank's caller ID? Does the bank have to call the bureau contact number of a card holder (with an extended fraud alert on the bureau) who requests a credit line increase or to have an account reactivated and new plastic sent or are these two scenarios exempt from FACTA verification compliance?