08/13/2023
If we provide Reg DD disclosure data such as the APY on business account periodic statements, would that require us to follow the other Reg DD requirements such as providing subsequent disclosure notices if we change an account service charge? Our host system is tying accounts together based on Social Security Numbers and Reg DD is triggered by the CIF and not by the individual accounts.
02/19/2023
Regarding the Annual Error Resolution notice required by Reg E, for online statements can this resolution just be added to the website or does it have to be actually sent to each customer with their online statement?
02/12/2023
We have changed our verbiage on our fee schedule to match the verbiage on our important terms and conditions regarding representments of checks. I was going to send out a letter with the updated fee schedule, but due to cost I would like to include the separate letter in the statement envelope. Does anyone see an issue with this?
12/11/2022
We have customers who initiate the same Reg E wires, for the same amount, to the same country, each month. The required disclosures are read to the customer each time. Can this disclosure requirement be waived if the customer sets up the wire as a Standing Order or sets up the wire to be an STO?
10/30/2022
We have customers who initiate the same Reg E wires, for the same amount, to the same country, each month. The required disclosures are read to the customer each time. Can this disclosure requirement be waived if the customer sets up the wire as a Standing Order or sets up the wire to be an STO?
03/07/2021
We need specific information on when we MUST post "MEMBER FDIC" on actual videos, ads etc. that we post direct to social media "if" this is already on our Facebook/Linked In pages in the "About" section. Please expand on this topic in detail.
06/28/2020
We have a HELOC originated in 2008 that moved into the repayment phase in May 2018. The initial rate was WSJ prime and remains at WSJ prime (no margin) throughout the repayment phase. The loan has a interest floor of 3.75 percent so the rate has been set at that since May 2018. Since there is no set change date to enter in our system the CFPB ARM notice will not generate to give advance notice if the rate increases. Are we required to provide the ARM notice, and if so are these circumstances that allow the notice to go after the fact?
06/28/2020
My question pertains to customer notices and brochures. I thought that if a bank posts one notice or brochure in another language it must post all notices and brochures in that language. In other words, if we do one sign in a second language (say Spanish), do we need to post all signs and/or brochures in Spanish?
12/01/2019
We are currently in the process of changing our fees. Some fees may increase and some fees may decrease. With that said do we still need to
send a notice to customers 45 days in advance of the changes?
03/18/2018
We are in the beginning stages of implementing online account opening. We are working with the vendor regarding E-SIGN acknowledgment. Currently, the test environment is configured so that the customer receives a validation code in an email. All of the required disclosures are attached to this email as a pdf. I am of the opinion this does not comply with E-SIGN's demonstrable
consent requirement.
Their response to my concern is as follows:
Our other clients have concluded that by obtaining consumer consent to E-SIGN and confirming the consumer received the email (using the verification code) reasonably demonstrates that the consumer can access the information in the electronic form. The disclosures in the email are PDF files. PDF format is an ISO standard that enable users to exchange and view electronic documents, independent of the environment in which they were created or the environment in which they are viewed or printed, while preserving content and visual appearance. Adobe relinquished control of the PDF format in July 2008 to the International Organization for Standardization to encourage the propagation and dissemination of this common technology. Today all modern operating systems, including mobile, support display of PDF files. Adobe Acrobat Reader is not a requirement to open and view PDF files.
Thus, my question is would you deem this configuration to meet E-SIGN consent requirements?