05/28/2007
One of our customers with an individual account and no authorized signers is having his girlfriend's payroll direct deposited into his account. How do we monitor this to keep it from happening on other accounts? Also, how should we handle any more of her deposits into this account?
05/21/2007
Our loan customer has their monthly loan payment debited from their checking account, at another bank, through an ACH transaction our bank initiates each month. The customer paid their loan in full without notifying us in advance and an ACH payment transaction occurred the day after they paid off the loan. We now have this customer's payment that needs to go back to them. We contacted the customer and asked them to call their bank and have them return the payment, however, the customer evidently has not done so and we still have the funds. In the past we would have sent the payment back to the customer's account via ACH, however, the last time we did that the customer had their bank return the payment to us. Their bank would not credit it back to us even though they saw we had already sent it back to them and we had a hard time getting the money back from the customer. What would be the safest way to return the money to the customer in cases such as this? Are there any standard procedures to follow in this instance?
05/14/2007
If a check is memo-posted, either via ACH (RCK) or electronic file from the Fed (cashletter), on our system and a customer comes in and wants to place a stop payment order on that check, do we accept it?
04/02/2007
Our internal auditor has asked for our "current ACH Origination Agreements that clearly states that the originator is liable for complying with AFAC requirements." Where would we obtain this document? How can we monitor compliance from all the ACH originators?
01/29/2007
When placing a stop payment on a check, how many days is the hold if the customer only gives a verbal authorization? Is it the same amount of days for ACH items?
01/22/2007
When a financial institution is sent a reclamation from the government for a deceased client are we required to send what is requested, even if the money is not in the account, or can we just send what is currently available in the account?
01/02/2007
If a customer issues payment from their account either by check or ACH, which is returned as NSF, what is the maximum number of times that the item can be represented for payment from the account? By check, ACH and combination of both.
12/04/2006
Our bank currently advertises a "Totally Free Business Checking Account." This account has no minimum balance requirements, and no transaction fee assessed to the account for the first 500 transactions (including checks paid, checks deposited, ACH debits and credits). If customers go over the 500 items, a per item processing fee is assessed. I've read the official staff interpretation of Reg. DD and I don't think that we can advertise this account as "free" or use "free" in the name of the account if we charge a fee when consumers exceed a specified number of transactions. Am I correct?
11/06/2006
Are regular/youth savings accounts subject to the same "consequences" of exceeding limits as Money Market accounts? In other words, if transaction limits are exceeded for a regular savings account, does that account have to be closed? In my previous experience, we have charged the customer a pre-set over-usage fee but did not close the account.
09/11/2006
We're being requested by the US Treasury to handle, over the telephone, amongst other things:* non-receipt of ACH credit claims, * request for account ownership info, and others that they want to give to us. We do not have to resolve the actual issue real-time over the phone but at a minimum, take in their claim/request. They're referring to the Social Security Act (Section 1441, Title 26, Title II the Railroad Retirement Act of 1974 and the Right to Financial Privacy Act (12 U.S.C. 3413 (K)) and saying that we're required to comply. Are you familiar with this and what are we required to do?