Although I have read through most of the information on the site referring to funeral trust accounts, there is always another question that comes up. We have a branch that wants to have the funeral home sign a letter authorizing all the CDs in place of having to sign a signature card for each one. Would any problems be created if we adopted this practice? In addition, any other suggestions regarding a good procedure for opening funeral trust accounts would be appreciated.
I need some ammo to use, such as the 12 CFR gauge or more powerful. My lending executive officer has authorized for use in a consumer transaction an application that does not meet any of the requirements found in Appendix B of Sec. 202 of Reg. B. For example, no space for Co-applicant information; no disclosure for other income (alimony, child support or other maintenance income; no statement as the correctness of the information above the applicant signatures; no authorization for credit verification, or employment verification, etc.; and no lines for applicant(s) signatures. That's right, consumer application without applicant's signatures. When the new operations VP came on board in 1980, he brought along the Lending Officers Worksheet(WKS). The sole purpose of the WKS was to be used to document credit requests in the case of business and corporate use. Ten years later one lending officer began the practice of using the form as a consumer application as a way to cut corners. That officer is still here. I have made recommendations during my Fair Lending Audit year after year to cease using the form as an application for credit. I have used Reg B as my basis of argument to no avail. I think I need some big guns, such as, law suits, where banks lost money due to technicalities where the documents are not signed properly. Any suggestions or examples would be appreciated.
Question: Are there any requirements / procedures / rules, UCC or otherwise, regarding the use of deposit tickets?
We have a customer who says that, at one time, she was told that, b/c she was hard of hearing, she could receive online banking at no charge. I don't know who told her that but for the last year, up until June 2002, we weren't charging anybody for online. When we started charging, in June or July, she called and told us about her fee waiver. Our Audit Department says that we are not under any obligation to waive the fee for disabled persons. But my question is: Since she claims to already have been told we would waive it, do we have too? And: If we waive it for her are we, then, obligated to waive it for other people with similar problems? As an example, I have a customer who is legally blind and would like online free b/c she can pull it up on her computer and she has a program that will read her the info off the screen. This customer says that she can't afford the $2.50 per month that we charge. What do you think?
While checks payable to a business must be deposited to that business's account, our bank has been allowing signors on a business account to transfer funds to their personal account. Business customers must reconcile account and report problems, I think this situation could lead to losses for the bank and/or the customer.
Question: We offer a debit card to our customers.
Question: Are there any Uniform Commercial Code Regulations about financial institution customers having to use deposit tickets?
Where's a good source for obtaining the basic knowledge needed for a novice to conduct an audit for the areas electronic banking and Internet banking?
Where I can find revelant bank internal audit reference material via online or publication that's current with today's banking? Most audit programs/questionnaires that I've seen are outdated....
We have been requested by our Commercial Loan area to help out an existing customer. The existing customer is being taken over by another Company and the existing customer would like to keep the existing account number but change the name and the reporting 06 TIN number on this existing account. My question is there any requirement by IRS or any others that we close this account and open another? We have always closed these accounts in the past but I think this was more a Bank requirement then a legal one. Am I correct in this?