Would the statement "1/4% bonus on CD," listed in a new account advertisement trigger additional APY disclosures?
I am with the trust compliance risk management department and perform compliance reviews for advertising and presentations that frequently involve products from multiple business lines: e.g., a wealth management piece may include reference to private banking, estate and wealth planning, insurance, investment management and brokerage services. How do you handle the multiple regulatory disclosures (FDIC, Equal Housing, Interagency statement, etc.) without completely cluttering the material with disclosure?
We would like to advertise our current HELOC rate on a website banner space that we pay for monthly. When the banner is clicked, it links the person directly to our own website. Here is my question. If we want to put our HELOC rate on the banner ad, can we just say... 4.50% APR fixed* on a HELOC at WSB click here for details Then when they click on it our website would come up with the fine print, details and disclosure information. Is this permissible or does all the "fine print" need to be on the banner with the rate?
If we charge a fee to our customers for on-line bill payment or ATM usage, do we need to disclose that and the amount in our customer agreement (initial disclosure), or can we just do it by providing our customers with a fee schedule when they sign up for a service?
Is it prohibited for a bank to "deal in lottery tickets" under FDI ACT Sec 20? We as a bank want to sell lottery tickets for a hospital and provide the prizes but it is a charitable donation. Is this allowed and what disclosures need to be included on the signs?
If a savings account becomes overdrawn due to an ACH item, can the bank charge an NSF fee the same as for checking accounts?
FACT Act - Risk Based Pricing Disclosures - Do you interpret this as being required beginning 12/01/04 or do we have a delay as the final rule has not been issued on this section?
Since its introduction several years ago, the regulatory agencies have expressed serious concerns about bounce protection programs which, unlike traditional overdraft programs, can lead consumers i
Our disclosures state that renewing CDs will automatically renew for the same term at the rate being offered to new deposits on that maturity date. We would like to offer a higher rate on a specific term at some of our branches for new deposits in that term; this would mean that any maturing CD in that term would renew at a lower rate. <ol><li>Can we do this and how do we handle the disclosure that customers have already received? <li>Can different rates be offered at different branches for the same term?<li>Is this an acceptable practice?</li></ol>