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Vendor Guru Q&A - Operations

Electronic Management of SAR Files

Latest Operations - Applications Topics

Displaying Equal Housing Lender Logo

02/28/2011

I once read something that stated the Equal Housing Lender logo (EHL) should be displayed anywhere a home loan application is received. Should a national bank have the EHL logo displayed on each loan officer/customer service desk where home loan applications are received or is the lobby poster sufficient?

$25 Promo for Credit Card Applications

10/18/2010

The bank wants to give a gift under $25 for all customers who fill out applications for credit cards or loans. This promotion will be held at branches in certain areas, but not statewide. Flyers will be available at all the personal bankers' desks. What would be the compliance requirement?

Is 'Instant Approval' Deceptive?

08/09/2010

Marketing wants to advertise that we have instant approvals for online applications. In fact, we will look at the credit score and terms requested, but some applications will be told their request is pending or is referred to a lender for review. I'm not keen on this ad from a compliance perspective, but what can I say to back this up?

About Tax ID Numbers

06/07/2010

Is there a certain sequence for state tax ID numbers? Do they start with a certain number per state/county?

Credit Card Phone Apps & Schumer Box Disclosures

09/08/2008

We have scripted disclosures for telephone applications on credit cards that include the Schumer Box disclosures. Marketing is trying to get us to reduce the talk time on the call. Reg Z says the disclosure requirements do not apply if the call is initiated by the consumer. Do they really mean that we can allow someone to apply by telephone without being given the Schumer disclosures? Do you have any guidance or thoughts on the matter?

CRA Branch Notice Requirements

05/07/2007

I am an auditor of a bank and did the branch audit yesterday. What are the requirements under CRA for the notice to be posted in a branch of a bank which is OTS regulated? I have a copy of the notice and want to make sure that it complies with the Reg.

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Citizenship Assistance

Pan American Bank in Los Angeles created a new micro-loan program designed to help immigrants afford to become U.S. citizens.

CFPB Publishing Consumer Complaints

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Screwed-up account opening

10/14/2018

A new CSR opened an account and let the customer do all kinds of weird things with Pay on Death beneficiary designations that aren’t legal in our state. Now what?

Regulation E vs. ACH

10/14/2018

If we are in compliance with the ACH Rules, then aren’t we in compliance with Regulation E?

Right of Set-off-Beneficiary Funds/UTMA

10/14/2018

I have a 20 year old customer that had a checking account that went negative and we couldn't reach him. We ended up charging off the account. This 20-year old is also the beneficiary of a Uniform Transfer to Miner's Act account that his grandfather is the custodian for. Since the beneficiary is considered the sole owner of the funds and it is to be used for their benefit, can I use "right of setoff" and take those funds and put them towards the charged off balance on his checking account?

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