ATM Reg CC Disclosure
05/05/2003
Do all of our bank's depository ATM's have to have a disclosure for funds availability even if funds deposited by customers are available the next day?
John Burnett joined Glia Group, Inc., and BankersOnline in 2004, and currently serves as Executive Editor. He is a 1990 honors graduate of the Stonier Graduate School of Banking and is an alumnus of the ABA National Compliance School, where he served on the faculty for several years.
John began his banking career in high school when he started as a teller at a $15 million bank that didn't have account numbers for its checking accounts (he says they actually filed by signature!) He moved to Cape Cod Bank and Trust Company in 1971 and assumed the position of Compliance Officer in 1976. He also served as corporate secretary and secretary of CCBT's Board of Directors, and as clerk of the bank's holding company.
He was a member of the Massachusetts Bankers Association Legal and Regulatory Compliance Committee, and of the American Bankers Association Compliance Executive Committee and NCS/NGCS Advisory Board. He is a regular presenter of BOL Learning Connect webinars and a participant in BOL Conferences events.
You may contact John via email at jburnett@bankersonline.com.
05/05/2003
Do all of our bank's depository ATM's have to have a disclosure for funds availability even if funds deposited by customers are available the next day?
05/05/2003
An elderly, disabled customer gave his housekeeper his ATM card and PIN to make withdrawals enabling her to run errands, pick up medicine, groceries, etc. She helped herself to his account in the tune of $2,300 from January through March. He filed an ATM dispute in April. Is the customer fully liable for his loss?
05/05/2003
The FDIC examiners are here! I am being told that we should disclose to our ATM customers on the ATM screen when their ATM transaction is accessing their overdraft line of credit. I could not find this requirement in any regulation anywhere and they could not give me anymore of an answer than "it would be a good idea." Is this usual or is someone overstepping their authority? We do mail the customer a notice each time they access funds from their overdraft line of credit whether the transaction took place at the ATM, teller line, POS or thru the inclearing.
05/05/2003
Our customers are able to deposit checks at supermarket ATMs. These items are processed for us by a third party financial institution. Scenario: Check in the amount of $1,800.00 is deposited on 2/07/03. The item was processed as a Lost item and returned to us on April 3rd, 2003. Can I send this item back to the paying bank as an untimely return?
05/05/2003
Are we required to verify source documents for master file changes (file maintenance)? Our system produces a daily report listing what was changed (the from and to) and who changed it. Do we really have to compare the source document to the report produced by our system?
05/05/2003
If a stop payment is placed on a cashier's check, does it have to be placed within 90 days of the issue date? Does the party placing the stop have to provide a bond in twice the amount of the check?
05/05/2003
When opening an account with a fictitious name certificate must the account be a business account to have a DB?
05/05/2003
In regard to opening a sole proprietorship account, if the city in which the business is conducted requires a business license, should we require a copy of the license for our files?
05/05/2003
An off site ATM machine was stolen last night. Do we have to file a SAR?, or is a police report sufficient?
05/05/2003
What disclosures, if any, should we provide to a commercial customer who requests a debit card?