Regarding FACTA Notice to Home Loan Applicant, if the bank does not pull a new credit report on a request to refinance an existing mortgage (or consumer loan secured by a 1-4 family residental property) do we need to issue the Notice to Home Applicant?
We are discussing some compliance issues at my bank. If we want to increase our fees, do we have to disclose the new fees to customers in writing?
I am trying to find the required disclosures to include the following message on exterior signage "100% Financing Available, Low Down Payments and No Hidden Fees." Can you help?
At a new account opening, if overdraft protection is discussed is that considered promoting overdraft protection? We do not have any written advertisements and/or disclosures discussing overdraft protection, we only mention it at account openings.
Would printing the phrase "earns interest on balances over $1,000" in a newspaper advertisement require additional disclosures?
Our marketing person wants to place a poster in each branch to promote IRAs. She found a brochure from a regional bank in which a graph was used to display how an annual contribution of $3,000 at 4% could grow at the start of age 25, in 10 year increments, to the age 65. The 4% does not reflect our current rates offered and IRAs can only be deposited as CDs with terms from 6 - 60 months. Am I working with an ad or just an illustration?
For the last 12 months we have been offering a "free checking" account that we are heavily advertising. The customer who opens the account receives a free gift. We are finding that many customers are opening the account, receiving the gift, and allowing the account to remain "inactive" with a small balance. Our operations group is proposing an $4 inactivity fee to kick in after 6 months of no activity on accounts with balances under $100 to help get these accounts off the books. Of course, we would have to change our disclosures and redisclose to existing customers if we do this. We currently disclose a "dormant" fee that kicks in after 2 years of no activity. I can't find any guidance whether or not a free account can have such an inactivity fee after a certain period. Are you aware of any other institutions charging such a fee? Can such a fee be structured in a way not to violate DD? Our marketing vendor assisting with this free checking account is also a proponent of this inactivity fee.
When advertising for a time deposit what information must be disclosed?
We are going to run a radio ad for a CD stating the annual percentage yield. Will this trigger any other disclosures? If so, which ones?
Our bank is offering a grand opening promotional savings account. As part of the account terms after the initial 6 month promo period the promotional account will convert to a standard savings account. The current promo disclosure states "at the end of the 6 month period the account will convert to a regular savings account". The promo product will pay interest on any balance of $1.00 or more, however, the regular savings products will pay interest on any balance of $500.00 or more. Does the minimum balance to earn interest on the regular savings account need to be disclosed on the promo product disclosure?