Required Disclosures For General Inquiries
04/14/2003
What disclosures are required if a potential customer just inquires about the various types of accounts and services we offer?
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.
04/14/2003
What disclosures are required if a potential customer just inquires about the various types of accounts and services we offer?
04/14/2003
If a customer is forced at gun point to give out his PIN number at an ATM to make a withdrawal, is the bank liable for the loss? Also, why is the bank liable if a customer writes his PIN number on a card and unauthorized withdraws are made. Why wouldn't this be negligence on the part of the customer to protect his PIN Number?
04/14/2003
When a deposit to a joint account requires a CTR to be submitted, is the transaction always considered to be on behalf of all account owners?
04/14/2003
Is a bank required by law or regulation to cash a tax refund check for a noncustomer?
04/14/2003
An examiner (OCC) told me all employees have to be trained on each regulation every 18 months. Where can I find this requirement in the regulations?
04/07/2003
Are we required to monitor Internet Bill Payment transactions for CTR reporting?
04/07/2003
Can we offer debit cards to savings accounts customers? We would assume they would fall under Reg D. We are considering doing away with ATM cards
04/07/2003
We are starting the process for providing our internet banking customers their checking account statement electronically. We currently provide an abbreviated Reg E disclosure on the back of each monthly statement. In an electronic environment how would you suggest we accomplish this?
04/07/2003
What are the regulations in regards to offering an electronic savings account? We would like to offer one that limits the deposits to electronic only and encourages ATM withdrawals, We would target customers with electronic Social Security or SSI payments into their accounts.
04/07/2003
We are in the process of setting up the process that allows our customers to access their HELOCs via a Visa Card. The card is actually a debit card though - in that it first accesses the customer's DDA account. That particular DDA account is set up and used only for this process, and works in the following manner: The customer uses card that taps into a DDA account that has a zero balance. The account automatically advances the amount of the transaction into the DDA account. So the account is debited, shows a negative balance, which is then zeroed out by the auto transfer from the HELOC. My question is two fold: With this type of process is our card considered a 'credit card'? And if not, and it is considered an actual debit card, can we send cards to existing customers unsolicited?