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#2215860 - 06/17/19 06:06 PM incentives for ACH payments
MusicCityCRCM Offline
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Joined: Apr 2015
Posts: 228
Our credit managers are discussing offering an incentive plan for loan officers who encourage their customers to have their loan payments set up for ACH, because the cost of coupon books from our vendor is increasing. My concern with this is we may have people who are tempted to either sign customers up for this form of payment without discussing it with them, or telling customers this is the only method of payment available in order to receive the incentive. This payment method is advantageous to the customer, as they receive a rate reduction, but I am concerned about the risks. Anyone have any thoughts on this?

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#2215869 - 06/17/19 06:34 PM Re: incentives for ACH payments MusicCityCRCM
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
One way to address it is to have a special authorization form used for these borrowers that sets out the pros and cons, and make sure each customer gets a copy of his her authorization with that info on it (the copy is required by Reg E §1005.10(b). Be sure to include on the form instructions on how to cancel the authorization.
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John S. Burnett
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#2215871 - 06/17/19 06:37 PM Re: incentives for ACH payments MusicCityCRCM
MusicCityCRCM Offline
100 Club
Joined: Apr 2015
Posts: 228
Thank you!

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