Prepaid Account Rule coverage
10/08/2017
In general, what types of accounts are covered by the new Prepaid Account rule?
Don Blaine is the Senior Training Consultant for Compliance Resource, LLC, a source of compliance assistance for financial institutions. Don has over 30 years of experience in regulatory compliance for the banking industry with banks ranging in size from community banks to money center banks. He is considered a subject matter expert in many of the consumer affairs laws and regulations and will be primarily specializing in training activities that will encompass the Bank Secrecy Act/Anti-Money Laundering laws and regulations as well as many of the laws and regulations related to deposit compliance. His prior roles have included: Chief Compliance Officer, Senior Compliance Regulatory Examiner, Compliance Audit Manager, and business unit compliance manager. He has taught at the ABA’s National Compliance School and has also served as an instructor on BSA and compliance topics at various programs offered by state banking associations. Prior to joining Compliance Resource, LLC, Don served as a consultant to numerous banks in areas ranging from BSA to lending and deposit compliance. He has attained Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) certifications.
10/08/2017
In general, what types of accounts are covered by the new Prepaid Account rule?
10/01/2017
Our bank would like to keep away from overdraft situations where we are debiting a customer’s checking account for any overdraft situations. Do we have any options?
09/24/2017
Is there a second prong that applies to the definition of what is, or is not, a Prepaid Account?
09/24/2017
My understanding is that to be covered by the prepaid rule the account must be marketed and labeled as “prepaid” or is redeemable at multiple, unaffiliated merchants for good or services. Is that correct?
09/10/2017
Does the Person-to-Person (P2P) definitional requirement also cover transfers to businesses?
09/03/2017
We are a small community bank and the submission to the CFPB of our Prepaid Account agreements looks to be burdensome. Is there any way out of providing such disclosures?
07/30/2017
What new regulatory expectations or requirements were added based on the November 2016 revision?
07/23/2017
I’m part of a bank holding company that has one bank with a FDIC charter and another bank where the Federal Reserve is the prudential regulator. How are we expected to make these different regulatory agencies happy or is this one size fits all?
07/16/2017
What’s the purpose of the Consumer Compliance Rating System in the first place, don’t examiners just know whether we fall into a specific numerical compliance rating category based on the “smell” test?
07/09/2017
How does a bank’s CRA and BSA rating impact its numerical Compliance Rating?