Reg E: Online Bill Payment & Overdraft Responsibility
03/03/2003
When customers pay bills through the bank's web site, a draft is generated to pay the bills. Who has the liability if the account is overdrawn? Would Reg E or EFT rules apply?
Mr. Andy Zavoina, CRCM, is an Executive Vice President and Chief Relationship Officer with the Glia Group, Inc., best known for its interest in BankersOnline.com. He joined Glia and BOL in 2003.
Mr. Zavoina has been in finance and banking for 42 years. Over 20 years were with a two-bank holding company which had $534 million in assets, 89 branches spanning Texas and nearly 500 ATMs. He managed loan workouts, has been a consumer, commercial and real estate lender, managing those departments, as well as being his banks first Webmaster. He was responsible for compliance -management, -auditing, and -training for both banks.
Andy is a frequent webinar presenter for BOL Learning Connect and a key contributor to conferences put on by BOL Conferences, Inc. In addition, Andy teaches live presentations at state association schools and regional compliance organizations across the U.S. and has served on the faculty of national banking schools. He has written articles and lectured on many facets of compliance, the use of the internet and technology as a tool, as well as compliance in cyberspace.
As a BankersOnline Guru, Andy assists banks in every day, and not so every day, compliance questions on BankersOnline, BankCompliance.com and other organizations.
Mr. Zavoina is a recipient of the American Bankers Association’s Distinguished Service Award for his involvement and accomplishments in the field of regulatory compliance management. He is a past Chairman of the ABA’s Compliance Executive Committee, the Editorial Advisory Board for the ABA Compliance Magazine and served as a member of the ABA’s Compliance School Board. He also served on the Texas Bankers Association's Compliance Committee.
He is a graduate of the ABA National Commercial Lending School, National Compliance and National Graduate Compliance School and is a Certified Regulatory Compliance Manager with the Institute of Certified Bankers.
You can reach Andy on the Internet by using his e-mail address, andyz@bankersonline.com, or visiting http://www.bankersonline.com.
03/03/2003
When customers pay bills through the bank's web site, a draft is generated to pay the bills. Who has the liability if the account is overdrawn? Would Reg E or EFT rules apply?
03/03/2003
We are currently reviewing our employee accounts by looking at their bank statements and all of their checks and deposit slips. Is this acceptable?
03/03/2003
Is there any information available on how to identify suspicious activity regarding charitable organizations? Is there any activity that tellers specifically may be able to watch for?
03/03/2003
We have a customer who says there are 4 ATM withdrawals done on the same day (Dec. 20) that are not hers. The convenience store where the ATM is located does not have a film for that day to see who did do the transactions. The customer swears she did not let anyone use her ATM card. We investigated and gave her back all but $50.00 before the 10 days was up and hot carded her card. Were there any other alternatives for us?
03/03/2003
We currently have a referral program whereby if an existing customer refers a friend to open a new account, the existing customer receives $5 gift certificate for groceries for their referral. We want to expand the program to include a monthly drawing where the existing customer who referred their friend has a chance to win a $250 grocery gift certificate in addition to the $5 gift certificate. Is it legal? What regulations apply?
03/03/2003
We are in the process of opening our first in-store(grocery) branch. Where can I get information concerning how I keep our bank in compliance when we are using the PA system, posters in the store, passing out brochures in the aisles?
03/03/2003
Does the revival of the homeownership counseling requirement apply to commercial/business purpose loans that are secured by the borrower's primary residence?
03/03/2003
What banking positions are required a national bank's board of directors required to appoint? I know that certain regulations require, for example, the appointment of CRA, BSA and Security Officers.
02/24/2003
I am a loan processor and the majority of our newest business in over the phone. The customer calls into talk to a loan officer. He/she gets all the information he can at the time and pulls credit. Sometimes, if the credit is really bad, they are declined over the phone and a adverse action or denial letter sent by the end of the week. On the other hand, some prospective clients take a few weeks and sometimes a month to make up their mind. What is considered the actual application date? The date the tell us over the phone to proceed, the actual credit pull date or the date they want to come in and sign?
02/24/2003
We are changing our hours of operation from 5 p.m. on Mondays to 4 p.m. on Mondays. Is there any reg that has guidelines on this or can we just start locking the door an hour earlier?