We would like to hang Home Equity Line banners with the phrase "Rates as low as" and then show our 6 month Intro APY. Are banners and outdoor ads subject to full disclosure under Reg Z? How much disclosure do I really need to include?
What are the ramifications of allowing additional deposits to a certificate of deposit when the contract specifically prohibits that? No additional disclosures are given to the customer upon receipt of the additional funds.
Can a customer be charged a NSF fee if the bank hasn't paid (but agreed to pay) the amount of POS transaction? The money was in the account at the time of the POS but other items came through before the final request for payment was received.
We have tiered our Home Equity Loan rates based on dollar amount. $25,000 and above get one rate then dollar amounts below $25,000 get a higher rate. Do I have to disclose both rates or can I just advertise the rate associated with the $25,000 and state that it is for amounts $25,000 and greater?
We use an insurance agency to market a long term care insurance product to our bank customers written through Blue Cross Blue Shield. In our compliance exam we were cited for not including the required insurance disclosures on the marketing brochure that we include in our checking statements 2 or 3 times per year. The insurance agency provides the disclosure and obtains acknowledgement of receipt from our customers when the customer contacts the agency regarding the long term care policy. The agency maintains the records of the acknowledgements and we advised the examiners that these records were available for their review. Were we cited because we did not include the disclosures on our marketing brochure at least in a shortened form? What's your take on this? We did not get a good response from the examiner and he would not remove the citation even after we provided the info from the insurance agency.
In a safe deposit box webinar, an answer regarding disclosures for safe deposit renters indicated that there were five states that have safe deposit regulations requiring written disclosure that insurance is not provided by the financial institution or FDIC. Where can I find model wording for this type of disclosure?
We are about to consider offering a youth savings account whereby for every book a child reads, the bank will donate $1.00 into the child's account. Is this a disclosure nightmare or what??? How would we advertise the rate/product?
We are implementing a Visa Gift Card program that starts in October. Of course we have already ordered 50,000 disclosures. The disclosures inform of dormancy fees. The state of Georgia has enacted laws concerning this type of fee. My question is this: We will change the parameters of the program to not charge the dormancy fees. Will we be able to use the disclosure forms we have printed up or do we need to order new forms already?
If we offer a promo where we'll reduce the interest rate on an existing loan by .50% if a customer opens a checking account with direct deposit, are we required to refinance the loan to disclose the lower rate, or can we do an addendum to the original loan note.
Our marketing department will like to hold a raffle that will have a prize valued at $500 at $100 and various small prizes valued at under $10. The raffle will be open to everyone and not require any type of purchase. Although, they would like to give a person that opens an account versus a person that doesn't open an account more chance tickets to win the raffle. Can they give say a customer that opens an account five raffle chances and a person who doesn’t open an account only one raffle chance? What are you ideas regarding this type of raffle? What type of disclosures would need to be given?