Skip to content
GeoDataVision
Thread Options
#487197 - 01/23/06 04:41 PM Reg B & Reg Cc ???
gunches Offline
100 Club
Joined: Dec 2005
Posts: 210
When opening a new account, are we required to give $100 cash back if the check is local?? Our check cashing policy states we can only give cash back up to the amount of available funds in a deposit account.

What is the latest version of Notice of Action Taken when denying a checking account.Ours is from 4/98 (Bankers Systems) and doesn't give the denial reasons as the loan denials do.Don't we have to give a reason??

Return to Top
Deposits and Payments
#487198 - 01/23/06 04:55 PM Re: Reg B & Reg Cc ???
Compliance A2Z Offline
Member
Compliance A2Z
Joined: Dec 2005
Posts: 56
A new account is an exception under Reg. CC.
$100 available under 229.10(c)(1)(vii).

I've always trusted Banker's Systems as being up to date on their forms.
(2) Content of notification when adverse action is taken. A notification given to an applicant when adverse action is taken shall be in writing and shall contain a statement of the action taken; the name and address of the creditor; a statement of the provisions of 701(a) of the Act; the name and address of the federal agency that administers compliance with respect to the creditor; and either:

(i) A statement of specific reasons for the action taken; OR

(ii) A disclosure of the applicant's right to a statement of specific reasons within 30 days, if the statement is requested within 60 days of the creditor's notification. The disclosure shall include the name, address, and telephone number of the person or office from which the statement of reasons can be obtained. If the creditor chooses to provide the reasons orally, the creditor shall also disclose the applicant's right to have them confirmed in writing within 30 days of receiving the applicant's written request for confirmation.

Return to Top
#487199 - 01/23/06 05:04 PM Re: Reg B & Reg Cc ???
GenerousLife Offline
Diamond Poster
Joined: Feb 2002
Posts: 1,466
USA
If your BS forms are generated from your core processing system and the updates are not current, you will have out of date forms. I think the current Notice of Action Taken has a 2005 date on it (to coincide with some FACT Act requirements).
_________________________
"No problem can withstand the assault of sustained thinking." ~ Voltaire
"Sustained thinking gives me a headache." ~Me

Return to Top
#487200 - 01/23/06 06:18 PM Re: Reg B & Reg Cc ???
Julie A. Stevens Offline
New Poster
Joined: Jan 2006
Posts: 1
Does anyone know where I get a sample REG CC Substititue Check notice?

Return to Top
#487201 - 01/23/06 06:37 PM Re: Reg B & Reg Cc ???
Compliance A2Z Offline
Member
Compliance A2Z
Joined: Dec 2005
Posts: 56

Return to Top
#487202 - 01/31/06 06:56 AM Re: Reg B & Reg Cc ???
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Quote:


What is the latest version of Notice of Action Taken when denying a checking account.Ours is from 4/98 (Bankers Systems) and doesn't give the denial reasons as the loan denials do.Don't we have to give a reason??




Reg B is the regulation that requires a reason for adverse action. Reg B does not apply if you refuse to open a deposit account. The only time Reg B would be an issue is if you are also denying a line of credit that would be tied to the deposit account.

Since Reg B does not apply when you decline to open a deposit account, only the FCRA notice is required. The FCRA notification only requires that you notify the consumer if you have declined their request based on information from a consumer reporting agency. The FCRA does not require that you provide a reason for declination.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

Return to Top

Moderator:  John Burnett