09/02/2003
I am the internal auditor at our bank and am currently reviewing lending operations. I am seeking to determine if there are any regulations or statutes that limit or prescribe amounts that can be charged borrowers as late fees for delinquent loan payments.
07/01/2003
01/06/2003
There are many new sofware products being offered today to assist in 'verfifying' the identity of new and/or existing bank customers (per proposed rules of the USA Patriot Act). These software packages search a number of various databases to get background and other 'verification' data. Some of the data bases that are 'searched' appear to be readily accessible general public record data bases, but others appear to be data bases that are not so accesssible by the general public. Is it permissible to have a customer sign a form which essentially says that the customer agrees that the bank can search for information to verify the customer's identity without specifically identifying the data bases being searched?
10/07/2002
The Consumer Protection in Sales of Insurance regulation (343.40(d)) indicates that advertisements and other promotional material for insurance products or annuities must include the insurance disclosures. We include promotional information about insurance products on our web site and if customers are interested, they would e-mail or call us for more information. Prior to selling the insurance, we provide the insurance disclosure in writing and obtain the customer's consent. Section 343.40(c)(4) describes providing disclosures in an electronic format and requires that a consumer affirmatively consents to receiving the disclosures electronically. Would the electronic consent requirement apply when we are only posting promotional material on the web site ?
09/02/2002
On an individual account for a son where the mother is an authorized signer what rights does the mother have on the account. My concern is that the son is going to war but does not want to make the mother a joint owner, with GLBA what in mind can the authorized signer receive statements, balance, information, etc.?
09/02/2002
What non-activity determines the status of an account to become dormant. Is it just no withdrawals made within a certain time frame. Or is it no withdrawals and deposits being made? What Reg is this discussed in?
04/01/2002
Is it permissible to charge our normal monthly service charge, in addition to a dormant account fee, on a dormant account?
02/01/2002
The concept is not new. It is familiar to almost everyone. A cost benefit analysis lays the foundation for deciding whether doing something is a good idea.
12/03/2001
Can a bank post checks in any order? OCC says yes, what do other regulators say?
01/01/2001