Most Popular Compliance Content
What is a Thrift?
03/09/2009
Can you tell me the definition of a thrift? I was recently hired by a financial institution that is classified as a thrift and I have had customers ask me what a thrift is.
Address Discrepancy Credit Report
03/09/2009
We are having a difference of opinion on this topic at our institution. When you are taking an application from a new consumer and receive an address discrepancy alert on a credit report, are you required to address that alert if you decide not to extend credit and a denial is sent?
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?